Better Work Haïti : 18e Rapport de synthèse semestriel

18th Biannual Synthesis Report Under the HOPE II Legislation Haiti REPORTING PERIOD October 2018 – April 2019 PRODUCED APRIL 2019 25 FACTORY ASSESSMENTS ILO CATALOGUING IN PUBLICATION DATA Better Work Haiti. 18th Synthesis Report under HOPE II Legislation International Labour Office synthesis report / labour law / hope legislation / haiti / garment labor / garment / industry / compliance April 2019 Copyright © International Labour Organization (ILO) and International Finance Corporation (IFC) April 2019 Publications of the ILO enjoy copyright under Protocol 2 of the Universal Copyright Convention. Nevertheless, short excerpts from them may be reproduced without authorization, on condition that the source is indicated. For rights of reproduction or translation, application should be made to the ILO, acting on behalf of both organizations: ILO Publications (Rights and Permissions), International Labour Office, CH-1211 Geneva 22, Switzerland, or by email: pubdroit@ilo.org. The IFC and ILO welcome such applications. Libraries, institutions and other users registered with reproduction rights organizations may make copies in accordance with the licences issued to them for this purpose. Visit www.ifrro.org to find the reproduction rights organization in your country. The designations employed in this, which are in conformity with United Nations practice, and the presentation of material therein do not imply the expression of any opinion whatsoever on the part of the IFC or ILO concerning the legal status of any country, area or territory or of its authorities, or concerning the delimitation of its frontiers. The responsibility for opinions expressed in signed articles, studies and other contributions rests solely with their authors, and publication does not constitute an endorsement by the IFC or ILO of the opinions expressed in them. Reference to names of firms and commercial products and processes does not imply their endorsement by the IFC or ILO, and any failure to mention a particular firm, commercial product or process is not a sign of disapproval. ILO publications can be obtained through major booksellers or ILO local offices in many countries, or direct from ILO Publications, International Labour Office, CH-1211 Geneva 22, Switzerland. Catalogues or lists of new publications are available free of charge from the above address, or by email: pubvente@ilo.org Visit our website: www.ilo.org/publns Cover photo: ©ILO/IFC Printed by ILO 1 BETTER WORK HAITI - 16TH SYNTHESIS REPORT COPYRIGHT Copyright © International Labour Organization (ILO) and International Finance Corporation (IFC) (2019) First published (2019) Publications of the ILO enjoy copyright under Protocol 2 of the Universal Copyright Convention. Nevertheless, short excerpts from them may be reproduced without authorization, on condition that the source is indicated. For rights of reproduction or translation, application should be made to the ILO, acting on behalf of both organizations: ILO Publications (Rights and Permissions), International Labour Office, CH-1211 Geneva 22, Switzerland, or by email: pubdroit@ilo.org. The IFC and ILO welcome such applications. Libraries, institutions and other users registered with reproduction rights organizations may make copies in accordance with the licenses issued to them for this purpose. Visit www.ifrro.org to find the reproduction rights organization in your country. ILO Cataloging in Publication Data Better Work Haiti: apparel industry 18th biannual synthesis report under the HOPE II legislation / International Labour Office; International Finance Corporation. - Geneva: ILO, 2019 1 v. ISSN 2227-958X (web pd7f) International Labour Office; International Finance Corporation Clothing industry / textile industry / working conditions / workers’ rights / labor legislation / ILO Convention / international labor standards / comment / application / Haiti 08.09.3 The designations employed in this, which are in conformity with United Nations practice, and the presentation of material therein do not imply the expression of any opinion whatsoever on the part of the IFC or ILO concerning the legal status of any country, area or territory or of its authorities, or concerning the delimitation of its frontiers. The responsibility for opinions expressed in signed articles, studies and other contributions rests solely with their authors, and publication does not constitute an endorsement by the IFC or ILO of the opinions expressed in them. Reference to names of firms and commercial products and processes does not imply their endorsement by the IFC or ILO, and any failure to mention a particular firm, commercial product or process is not a sign of disapproval. ILO publications can be obtained through major booksellers or ILO local offices in many countries, or direct from ILO Publications, International Labour Office, CH-1211 Geneva 22, and Switzerland. Catalogues or lists of new publications are available free of charge from the above address, or by email: pubvente@ilo.org Visit our website: www.betterwork.org 2 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Acknowledgements Better Work Haiti is supported by the US Department of Labor. Core donors to Better Work are: Netherlands Ministry of Foreign Affairs, Swiss State Secretariat for Economic Affairs (SECO), Danish International Development Agency (DANIDA), Australian Department of Foreign Affairs and Trade, German Federal Ministry for Economic Cooperation and Development, and the US Department of Labor. Funding is also provided by Canada Department Foreign Affairs, The European Commission, DFID, German Federal Ministry for Economic Cooperation and Development, GIZ; Royal Government of Cambodia, Garment Manufacturers Association in Cambodia and private sector donors, including The Walt Disney Corporation, Inc., Levi Strauss Foundation, Gap Inc. This publication does not necessarily reflect the views or policies’ of the organizations or agencies listed above, nor does mention of trade names, commercial products, or organizations imply endorsement by them. 3 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Table of Contents List of Tables and Charts .......................................................................................... 4 List of Acronyms ......................................................................................................... 5 1.1. Background ................................................................................................................. 6 1.2. Country Context and Industry Updates ............................................................... 7 Section II: Highlights from the Reporting Period ................................................. 11 2.1. Compliance Situation In Haiti’s Exporting Garment Sector ........................... 17 2.2. Compliance Performance With Regards To International Core Labor Standards ................................................................................................................... 21 Child Labor................................................................................................................................ 21 Discrimination .......................................................................................................................... 21 Forced Labor ........................................................................................................................... 22 Freedom of Association and Collective Bargaining ................................................. 22 2.3. Compliance Performance with regards to National Labor Standards ....... 23 Compensation ........................................................................................................................ 23 Paid leave................................................................................................................................. 23 Contracts and Human Resources .................................................................................. 24 Termination ............................................................................................................................ 24 Occupational Safety and Health..................................................................................... 25 Chemicals and hazardous substances ......................................................................... 25 Emergency Preparedness ..................................................................................................26 Working Time .......................................................................................................................... 27 REGULAR HOURS ................................................................................................................ 27 2.4. Advisory and Training Services in the Reporting Period ............................... 28 Better Work Advisory Services ..........................................................................................28 Better Work Trainings ......................................................................................................... 30 Section III: Conclusion and Next Steps ................................................................. 32 Annex 1. The TAICNAR Project and Reporting Requirements under the HOPE II Legislation ................................................................................................................. 34 Annex 2. Better Work’s Service Delivery Model .................................................. 37 Annex 3. The Better Work Compliance Assessment Methodology ................ 40 Better Work Compliance Assessment Framework ........................................................... 40 Calculating Non-Compliance & Public Reporting ............................................................. 46 Limitations in the Assessment Process ................................................................................ 47 Annex 4: Factories in Detail ...................................................................................50 List of Factories .......................................................................................................................... 50 Findings from the Factories ...................................................................................................... 51 4 BETTER WORK HAITI – 18TH SYNTHESIS REPORT List of Tables and Charts Table 1: Factory’s Bi-partite committee Status ....................................................................25 Table 2: Better Work compliance assessment framework .................................................. 37 Table 3: List of factories in the Haitian apparel sector which have been assessed between April 2019 and March 2019 ............................................................................................ 45 5 BETTER WORK HAITI – 18TH SYNTHESIS REPORT List of Acronyms ADIH Association des Industries d’Haïti (Haitian Industry BPC Bipartite Committee BMST Bureau de la Médiatrice Spéciale du Travail CAOSS Conseil d’Administration des Organes de Sécurité Sociale (Board of Social Security Bodies) CP Compliance point CSS Conseil Supérieur des Salaires (Wages High Council) Association) CTMO-HOPE Commission Tripartite de Mise en œuvre de la loi HOPE EA Enterprise Advisor HELP Haiti Economic Lift Program HOPE Haitian Hemispheric Opportunity through Partnership Encouragement Act ITUC International Trade Union Confederation MSDS Material Safety Data Sheet MAST Ministère des Affaires Sociales et du Travail (Ministry of Labor and Social Affairs) OFATMA ((Office for Work, Health and Maternity Insurance) ONA Office Nationale d’Assurance Vieillesse (National Office for OldAge Insurance) OSH Occupational safety and health PAC Project Advisory Committee PIC Parc Industriel de Caracol PIM Parc Industriel Métropolitain (also referred to as SONAPI) PPE Personal Protective Equipment SC/AFL-CIO Solidarity Center/American Federation of Labor - Congress of Industrial Organizations TDS Social Dialogue Table (Table de Dialogue Social) TAICNAR Technical Assistance Improvement and Compliance Needs Assessment and Remediation United States Department of Labor USDOL 6 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Section I: Introduction and Context 1.1. BACKGROUND Better Work – a collaboration between the United Nations’ International Labour Organization (ILO) and the International Finance Corporation (IFC), a member of the World Bank Group – is a comprehensive program bringing together all levels of the garment industry to improve working conditions and respect of labor rights for workers and boost the competitiveness of apparel businesses. The program was launched in Haiti in June 2009 as part of the global Better Work program with country operations in Bangladesh, Cambodia, Haiti, Indonesia, Jordan, Nicaragua, and Vietnam. To date, Better Work is focusing its efforts on the apparel and footwear industry in the countries it operates in. However, companies from other industries may benefit from Better Work services in some particular country contexts.1 In Haiti, the program is mandatory for all apparel producers exporting their products to the US market under the HOPE II legislation. The HOPE II law requires that Haiti in cooperation with the ILO establishes a Technical Assistance Improvement and Compliance Needs Assessment and Remediation Program (TAICNAR) which (i) assesses Haitian apparel factories exporting under the HOPE II law on compliance with international core labor standards and national Haitian labor law, (ii) assists these factories on their remediation efforts and (iii) provides capacity building to the Government of Haiti on these aspects. According to the HOPE legislation, biannual reports have to be published to state enterprise level compliance performance. Further details on the components of the HOPE II law as well specific requirements with regards to biannual reports being published by the entity operating the TAICNAR program are quoted in annex 1 (HOPE II Legislation Reporting Requirements). This is the second of these two annual reports under the HOPE legislation to be published in 2018. Detailed enterprise level data of compliance performance as required by the HOPE II legislation is included in the factory tables in annex 4. 1 In Haiti for example, a plastics factory is participating voluntarily in the program by paying a market price for the Better Work services. 7 BETTER WORK HAITI – 18TH SYNTHESIS REPORT The two components of HOPE II’s TAICNAR program aim at strengthening labor compliance of the industry in Haiti. The first of these elements focuses on assessing compliance with core labor standards and national labor law, supporting remediation efforts, and publicly reporting on the progress of each factory on the Labor Ombudsman’s register. The second element of the TAICNAR program consists of technical assistance to strengthen the legal and administrative structures for improving compliance in the industry. The scope of these services is extensive, encompassing technical assistance from the ILO in reviewing national laws and regulations to bring them into conformity with international standards, raising awareness of workers’ rights, and training labor inspectors, judicial officers and other government personnel. To encourage compliance with core labor standards and national labor law, the legislation indicates that preferential treatment may be withdrawn, suspended, or limited by the President of the United States from producers who – even after assistance has been provided - fail to come into compliance with the core labor standards and national labor law that is related and consistent with those standards. Removal of benefits is based on determinations made by the government of the United States, based primarily on non-compliance identifications made by the U.S. Department of Labor (USDOL). While Better Work Haiti reports are consulted as USDOL carries out its mandate to implement HOPE II, Better Work Haiti non-compliance findings cannot, on their own, serve to impact preferential treatment under the HOPE Act. Better Work Haiti has been implementing the first component of the TAICNAR program from 2009 until 2017 while other ILO projects, in particular the ILO-MAST capacity building project worked on the second component. As of 2018 with the start of the third phase of the Better Work Haiti project (2018 - 2022), Better Work will also take on several elements of the second component of the TAICNAR program while continuing carrying out activities covering TAICNAR component one. The Better Work program is coordinating its work with the Labor Ombudsman and a tripartite Project Advisory Committee (PAC). This committee meets with Better Work on a regular basis to discuss the activities of the Better Work program. The members of the PAC represent the private sector, government and worker representatives and the Committee is chaired by the Labor Ombudsperson in line with the requirements of the HOPE law. 1.2. COUNTRY CONTEXT AND INDUSTRY UPDATES 8 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Over the last year Haiti experienced a high number of political and socio-economic demonstrations due to concerns and frustration over ongoing difficult living conditions, and demands for increased transparency and accountability. The depreciation of the national currency (Gourde) against US dollar is raising prices of essential commodities, and in turn maintains the population in anxiety and daily frustration. The volatility of the political environment was illustrated by violent and widespread civil unrest occurred from 6-8 July, 2018, as a result of the Government announcement that it would discontinue retail fuel subsidies. During the first quarter of 2019, the opposition called for national protests after a court report alleged that officials and former Government ministers had reportedly misappropriated millions of dollars in loans made to Haiti by Venezuela after 2008. For 10 consecutive days, protestors took to the streets in the metropolitan area of Port­ au-Prince (West Department), as well as of other cities and villages around the country to demand the departure of President Moise, better living conditions, and an end to corruption. Small groups of violent individuals erected roadblocks throughout the country. Economic activity remained partially paralyzed as banks, schools and most businesses were closed. Public transportation traffic and roadside market activity continued to be significantly low. The international community is calling on the country’s leaders, civil society actors, and private sector society actors, and primarily the country's leaders, to engage in a constructive and inclusive dialogue in order to identify and implement realistic and lasting solutions to the political and economic crisis currently occurring in Haiti. In this regard, the Core Group (composed of the Special Representative of the United Nations Secretary-General, the Ambassadors of Brazil, Canada, France, Germany, Spain, the European Union, the United States of America, and the Special Representative of the Organization of American States) is encouraging the government to accelerate its structural reforms aimed at promoting better management of the State's resources, improve living conditions, fight inequalities, and foster a conducive investment climate to stimulate the development of productive sectors – essential to catalysing the country’s growth.2 Most BWH factories are in the Metropolitan Port-au-Prince area and the North East Department. The BWH factories in Port-au-Prince and at the Caracol Industrial Park 2 Public statement from Core Group 9 BETTER WORK HAITI – 18TH SYNTHESIS REPORT have seen very high levels of absenteeism and have struggled with production during the period. The lack of fuel and public transport had been the biggest challenge for BWH factories to continue to operate efficiently. However, the CODEVI industrial park located in Ouanaminthe (North East of Haiti) worked at 100% capacity during the unrest. The role of social dialogue as an effective tool for achieving socio- economic development, industrial democracy and social justice has been seriously embraced by the government, workers’ and employers’ organizations in Haiti during the period. Following several tripartite consultative workshops and meetings, the social partners agreed to bring the country’s legislation in conformity with international labour standards. Again through this tripartite approach the social partners have met with their respective group individually with a judicial consultant. The tripartite members agreed to harmonize labour laws and to further engage on a more comprehensive reform process targeting the weakness in the current Haitian Labour law. Total export revenues from the textile and garment industry in Haiti continue to account for approximately 90% of national export earnings and 10% of national GDP. Despite the turmoil in 2018, the apparel sector has seen $926 million worth of garment sent to the US, up 7.7% from $861 million in 2017. S&H Global S.A, a Haitian subsidiary of Sae-A Trading Co. Ltd., one of the largest Korean garment companies in the world, which has invested $78 million to develop its operations in the Caracol Industrial Park (PIC), has created more than 13,000 jobs. Instability and unrest in country, have forced the investors to use another back up plan for their expansion rather than in Haiti as initially planned. 10 BETTER WORK HAITI – 18TH SYNTHESIS REPORT HAITI INDUSTRY AT A GLANCE IN NUMBERS Better Work Haiti strives to create a garment industry that provides decent work to a projected 65,000 workers, lifting their families and communities out of poverty, empowering women, boosting national income and improving social stability. Building on the strong partnerships Better Work has developed with the government, global brands, employers and unions, over the next five years, the programme will play a central role in realizing the full potential of the HOPE II Act – a preferential trade program with the US. Convening diverse stakeholders to tackle shared challenges and supporting institutions’ efforts to monitor and safeguard factory compliance with international labour standards will be top priorities. 33 53,000 FACTORIES IN THE PROGRAMME WORKERS (65% WOMEN) 7 ~1 billion FREE ZONES HOSTING 90% OF TEXTILE APPAREL EXPORTS IN USD BILLIONS (90% OF NATIONAL EXPORTS) 18 16 BRANDS AND RETAILERS BETTER WORK HAITI STAFF 10 years 18 YEARS OPERATING IN HAITI SINCE 2009 INDUSTRY COMPLIANCE REPORTS Key partners           Ministry of Social Affairs and Labour (MAST) Office of the Labour Ombudsman (BMST) National Insurance and Pensions Office (ONA) Office for Employment Injury, Illness and Maternity (OFTMA) Ministry of Commerce and Industry (MCI) Office of the State Secretary for the Integration of People with Disabilities (BSEIPH) Association of Haitian Industries (ADIH) Economic Forum All Trade unions active in the garment sector 18 brand and retail partners 11 BETTER WORK HAITI – 18TH SYNTHESIS REPORT FIGURE 1. EMPLOYMENT GROWTH IN 5 YEARS JOBS PIM PIC CODEVI 53,000 52,000 46,000 47,386 45,000 9,120 7,500 10,900 7,800 13,026 9,200 8,923 11,351 13,491 9,233 Section II: Highlights from the Reporting Period  Better Work Haiti launched the Better Work Academy for national partners with the implementation of the Building Bridges project, funded by the Walt Disney Company, which aims to build the capacities of the national partners to empower participating organizations to reflect on and shape the future of the garment industry, as well as for other export sectors. On 9 November and 14-15 November, 2018 Better Work Haiti (BWH) and its national partners convened in Caracol and Port-Au-Prince to participate in Module 1 of the Building Bridges curriculum. 94 participants from employers, unions and government organizations attended the 3 workshops. 11,351 13,491 10,179 12 BETTER WORK HAITI – 18TH SYNTHESIS REPORT  Based on a discussion on industry compliance trends and challenges, participants jointly diagnosed governance challenges and developed a plan for further learning to translate their vision into action through the Building Bridges curriculum. Management and Union representatives from names of factories participating in the BWH program shared practical lessons learned with participants on their successes and challenges in promoting management-worker dialogue, skill development for workers and realizing improvements in working conditions. The following areas were identified as priorities for cooperation and action:  Labor law reform finalized and adapted to socio-economic realities;  Tripartite agreement to ensure that wage increases are predictable, safeguarding availability of social security and benefits to all workers through the modernization of social security agencies, and general implementation of electronic payments for improved transparency.  Effective platforms for sectoral dialogue and problem solving at the sectoral and national level  This program also aims to make Better Work expertise, data and skills acquired through work at the factory level available to participating organizations and to create an environment for participating organizations to convene in a joint learning process that contributes towards enhanced understanding and trust, allowing actors to share and learn from one another’s approaches.  A second event of the Building Bridges project is being planned for Q2 2019 13 BETTER WORK HAITI – 18TH SYNTHESIS REPORT FIGURE 3. BUILDING BRIDGES EVENT ATTENDANCE Staff of Labor Inspectorate Factory Management Trade Union Representative Business Associate Representative Representative of International Brand Other 0 1 2 3 4 5 6 7 8 9 10 TRADE UNION CAPACITY BUILDING  From Better Work’s perspective, significant progress was realized during the September mission of ITUC, IndustriALL and ACTRAV on improving their understanding of the BWH program and Haitian trade unions of their goals, activities, and opportunities available in the Better Work partnership.  Better Work core services staff also developed a much better understanding of the priorities and relationships among trade unions active in the garment and textile sector.  As of February 2019, the trade unions in Haiti have elected their new representatives to the PAC, (Project Advisory Committee) an important step that will facilitate forward movement on other important discussions. Further discussions will be required within the PAC on the reformulation of the structure and scope of bipartite social dialogue structures at enterprise and sectoral level, given the concerns expressed by the trade unions in relation to the PICCs and the Social Dialogue Round-Table. 14 BETTER WORK HAITI – 18TH SYNTHESIS REPORT  BWH is also working in the medium term with the trade unions in the garment sector to develop strong internal membership development programmes, which can ensure that basic operational needs of the trade unions are covered through membership dues.  Despite the intra-union conflicts during the period, BWH in collaboration with other ILO experts, provided technical support towards development of the labour law reform process by providing information on the guidelines and identifying the gaps between the conventions Haiti has ratified and the current labor code. A legal adviser was provided to the tripartite constituents.  As a part of its gender strategy implementation plan, Better Work Haiti collaborated with different stakeholders to organize activities in this area. In addition to training on sexual harassment awareness and prevention, Better work organized a workshop on the challenges faced by women in the workplace. Senior members of the factories, factory level union members, and the Ministry of Labour and social security institutions were present. This workshop provided the participants with the necessary knowledge and confidence regarding the specific stresses and challenges faced by women in the workplace. The Haitian garment sector working landscape is specifically challenged in that a very large number of the women are single parents. A total of 118 representatives of employers, factory level unions, union leaders and government organizations attended the workshops. The second workshop was facilitated by a consultant hired by Better Work Global who did similar work in all Better Work programs. This workshop gives new insight to both men and women as to the challenges that each face as individuals and in teams. This workshop invited the national partners to think and dialogue on what gender is and on their own attitudes toward it.  During the period, BWH worked with the Haitian government (Ministry of Labor, ONA, and OFTMA) to improve their organizational structure and have made available to the labor inspectors tools and equipment to prevent disputes and mechanisms for remediation in the garment sector.  BWH supported the Labor Administration to develop and implement a national labor inspection plan. Labor inspections in the west departments have increased by 35%. BWH collaborated with the Ministry of Labor (MAST) to develop and implement a national training plan including the social 15 BETTER WORK HAITI – 18TH SYNTHESIS REPORT security institutions (ONA, OFATMA’s). During the period, a joint inspection (MAST, ONA and OFTMA) to a garment factory was carried out for the first time ever to respond to the need for synergy between the government institutions to reduce cases of non-compliance in the factories, particularly in the garment sector. FIGURE 1. INDUSTRY INVESTMENT OWNERSHIP 6% 3% 6% USA (2) KOREAN (14) DOMINICAN REPUBLIC (2) 34% 44% HAITIAN (11) TAIWAN (2) 6% SRILANKA (1) 16 BETTER WORK HAITI – 18TH SYNTHESIS REPORT FIGURE 1. MANUFACTURING PRODUCTS BY FACTORIES 16 15 14 12 10 8 8 5 6 3 4 4 2 2 0 T-shirts Knits Shirts Pants Sports apparel Others  HOPE II country eligibility requires a range of commitments from the Government of Haiti including improving compliance with national labor law, which is directly related to an effective labor inspection system. This commitment provides an opportunity for BWH to encourage the MAST senior officials to ensure adequate resources are allocated to strengthening labor inspection including the capacity of the labor inspectors and conciliators.  BWH is supporting MAST, ONA (Office Nationale d’Assurance Vieillesse) and OFTMA (Office d’Assurance de Travail, de Maladie et de Maternité) to revise internal procedures and put mechanisms in place to improve their capacity to collect and analyse data, including sex- disaggregated data and statistics, and to produce evidence-based reports on interventions on workplace compliance.  Currently, the MAST trainers are replicating the trainings received from the ILO’s Labour Administration Department and BWH to train other inspectors in the region. Seven training sessions (e.g. Inspection Methodology, labour law and Industrial Relation, Occupational Safety and Health and the Core Labor Standards.) have been provided in six departments of the country (West, North, North-east, South, South-East, and Central Plateau 17 BETTER WORK HAITI – 18TH SYNTHESIS REPORT department). A total of 173 inspectors of ONA, OFATMA and MAST regional offices have been participating in these training sessions. 2.1. Compliance Situation In Haiti’s Exporting Garment Sector All factories registered with the Better Work program in Haiti are assessed once per year. This assessment is conducted after an initial advisory period of about 100 days and follow up advisory visits and trainings are offered after the assessment to facilitate continuous learning and improvement. For more information on the Better Work service delivery model as well as the Better Work assessment methodology, please consult annex 2 and annex 3 respectively. This section presents the results of assessments, advisory and training services provided to the 25 participating factories assessed at least twice in the period between April 2018 and March 2019 The charts present non-compliance findings for the 25 assessed factories in Haiti showing non-compliance rates in brackets. A factory is found non-compliant in a compliance point if it is found out of compliance on any one aspect of it. Please note that these reports are issued biannually, yet assessments are being done on an annual basis, so issues are reported in two consecutive reports. In the individual factory tables in Annex 4 of this report, progress on the remediation of noncompliance issues can be followed in further detail. Persistent noncompliance issues in areas related to compensation (social security) and OSH (Chemicals management and emergency preparedness) continue to be a concern for the sector. In addition to the focus on management systems during advisory and training, Better Work is working closely with the Ministry of Labor and Social Affairs, ONA and OFATMA to address these issues in a sustainable way. In fact, ensuring that all parties involved in labor inspection are aligned on the way to assess and address these issues is key to solve them. A first OSH training was organized by Better work and MAST for OFATMA inspectors in October 2017. Also, a joint workshop was organized in May 2018 with inspectors from MAST, ONA and OFATMA to review the legal framework on social security and agree on the approach for assessing compliance in this area. Better Work is also supporting the Ministry of labour in the implementation of a national training plan for MAST, ONA and OFATMA inspectorate to reinforce their capacity in compliance assessment. All these efforts should contribute to reduce the rates of persistent noncompliance 18 BETTER WORK HAITI – 18TH SYNTHESIS REPORT during 2019, as several actors will be actively involved in the monitoring of these issues. BETTER WORK HAITI – 18TH SYNTHESIS REPORT Forced Labour Discrimination Child Labour Non-compliance rates by Compliance Point - March 2018 - March 2019 Freedom of Association and Collective Bargaining 19 Child Labourers Documentation and Protection of Young Workers 4% Hazardous Work and other Worst Forms 0% Gender 4% Race and Origin Religion and Political Opinion Bonded Labour Coercion Forced Labour and Overtime Prison Labour Collective Bargaining 0% Freedom to Associate 0% Interference and Discrimination 8% Strikes Union Operations 4% 0% 10% 20% 30% 40% Non-compliance rate (n= 25) 50% 60% 70% 80% 90% 100% BETTER WORK HAITI – 18TH SYNTHESIS REPORT Non-compliance rates by Compliance Point - March 2018 - March 2019 Method of Payment Compensation Minimum Wages/Piece Rate Wages 4% Overtime Wages 24% Paid Leave 48% Premium Pay Social Security and Other Benefits Occupational Safety and Health Contracts and Human Resources Wage Information, Use and Deduction Contracting Procedures Dialogue, Discipline and Disputes Employment Contracts Termination 20% Chemicals and Hazardous Substances 96% Emergency Preparedness 96% Health Services and First Aid OSH Management Systems 64% Welfare Facilities 80% Worker Accommodation 0% Worker Protection 100% Working Environment Working Time 20 92% Leave 24% Overtime 8% Regular Hours 36% 0% 10% 20% 30% 40% Non-compliance rate (n= 25) 50% 60% 70% 80% 90% 100% 21 BETTER WORK HAITI – 18TH SYNTHESIS REPORT 2.2. Compliance Performance With Regards To International Core Labor Standards Better Work’s compliance assessment framework is based on eight clusters, four related to international core labor standards (see previous section) and four relating to national labor legislation. Each cluster consists of several compliance points and each compliance point is made up of several questions (see Table 3 in the annex for further detail on the structure of the Better Work compliance assessment tool). During the last round of assessments between April 2018 and March 2019 in 25 factories assessed at least twice by Better Work Haiti, the following results with regards to core labour standards have been observed. It is important to note that the child labour and discrimination issues described are not new issues as they were reported in the previous reporting period. Therefore description of the improvement priorities identified is provided. CHILD LABOR During the period under review, there was one finding related to child labor. Although no child was found working in this factory, the non-compliance issue is due to the fact the factory was not able to demonstrate that it had a proper system in place to systematically verify workers ’age during the hiring process. Keeping a reliable system in place to verify the age of workers prior to hiring is a key element to prevent child labor in garment factories. The factory was advised to improve the recruitment procedure to ensure that reliable documents and a valid ID is included in their files. DISCRIMINATION One case of gender discrimination was found during the reporting period. The factory found in non-compliance has a policy on sexual harassment, has organized sexual harassment prevention training at all levels of management and workers, and has followed through with termination when such incidents occurred. Also, all supervisors and managers are trained on sexual harassment and required to commit to respect the factory's policy on this matter. However, this policy has been undermined through management discretion at the module level to rehire a known offender. In addition, it was found that male management staff was conducting random bathroom checks, which created a humiliating work environment for workers. At the time of the assessment visit, there was no evidence that specific measures had been put in place to ensure 22 BETTER WORK HAITI – 18TH SYNTHESIS REPORT that known harassers are not rehired or that HR staff do not abuse their power, or that bathroom checks if necessary are only conducted by a person of the same sex in a respectful manner. The factory took immediate action following the assessment visit to terminate the harassers. BWH is providing additional advisory and training services to help the factory improve its current procedures. Also, a new training on sexual harassment is being implemented at several factories since August 2018 in order to prevent sexual harassment and raise workers awareness. Subsequent verifications done by Better Work enterprise advisor since the latest synthesis report revealed that the workers were aware of the anti-harassment policy and that the factory improved the procedures related to the training of middle and senior management on sexual harassment. Also, the compliance department was centralized and is now working under the direct supervision of the company president, which confers more independence to the factory compliance officer in their regular duties. The factory was advised to ensure that all module are respecting the zero tolerance policy; ensure that all employees working in the HR department and the supervisory lines of each module receive the HR training; review the zero tolerance policy and consult workers representatives on issues related to Sexual Harassment. The implementation of the improvement priorities identified was confirmed during advisory visit by the enterprise advisor assigned to this factory. FORCED LABOR There are no findings under the Forced Labor Cluster in this reporting period. FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING There are two cases of non-compliance under the cluster for Freedom of Association and Collective Bargaining, all under the compliance point of Interference and Discrimination. Two factories were cited in non-compliance under this compliance point for termination or non-renewal of worker's employment contract due to union membership or activities. Better Work found noncompliance based on the fact that in the first factory, management did not provided sufficient evidence that 2 union members and one union leader were terminated for violating the rights of non-striking workers. 23 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Better Work recommends the reinstatement of this union leader, with compensation for back pay. In the second factory, 11 trade unionists were fired after a strike for refusing to sign a letter saying that the strike they organized to request a raise for the minimum wage was illegal as requested by the employer. However, 9 of the 11 trade unionist who remain out of work have not agreed to end their contracts. Better Work recommends reinstatement of these 9 workers. During off hours, including during breaks, union representatives employed at the factory should not be required to ask permission to engage in union activities, assuming there is no interference with normal operations. 2.3. Compliance Performance with regards to National Labor Standards In this section, selected compliance points will be analysed in further detail. Chart No. 1, which gives an overview of the compliance performance of the full set of factories in the sample, shows that the same compliance points tend to remain at high non-compliance rates of over 50% from one cycle to the next. Most of these areas of persistent non-compliance (PNC) have been analysed in detail in past reports. Therefore, some compliance points with lower noncompliance rates will be included in further detail in this edition of the report. COMPENSATION In the Compensation cluster, the highest non-compliance rates persist in the compliance point of Social Security and Other Benefits (88%), as well as the compliance point on Paid Leave (48%). 24% of factories were found in noncompliance with regards to overtime wages. These numbers show a slight increase in the noncompliance rate in comparison to the previous cycle. Better Work Haiti is exploring ways to improve its collaboration with MAST, ONA and OFATMA in order to ensure that these issues are addressed in a more sustainable way. PAID LEAVE Compliance Question Does the employer pay workers correctly for annual leave? # of factories found NC NC Rate by Question 2 8% 24 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Does the employer pay workers correctly for legally mandated holidays? Does the employer pay workers correctly for maternity leave? Does the employer pay workers correctly for weekly rest days? Does the employer pay workers correctly during the daily break? Are eligible workers paid correctly for sick leave? 1 4% 7 35% 1 5% 1 1 4% 4% Does the employer pay any workers incorrectly for any types of paid time off (breaks and leave)? 0 0% Does the employer pay workers correctly during 2 breaks of 30mn or 3 breaks of 15 minutes for breastfeeding? 1 4% The highest rate of noncompliance in this section is related to the payment of maternity leave. Seven factories were found in non-compliance for inaccurate payment of maternity leave. In fact, in some factories, the calculation of maternity leave payments for workers entitled to incentives is based on the minimum wage of reference instead of average earnings as required by the law under Article 148. However, the increase in the noncompliance rate for this section is due to the fact that the factories that are not registered to OFATMA for maternity and health insurance only pay 6 weeks maternity leave instead of 12 weeks. CONTRACTS AND HUMAN RESOURCES In the cluster on Contracts and Human Resources, an average of 28% of factories were cited in non-compliance under the compliance point termination for different questions. Further details are outlined in the tables below. TERMINATION Compliance Question # of factories found NC NC Rate by Question Does the employer compensate workers for unused paid annual leave when they resign or are terminated? 1 4% Does the employer comply with legal requirements before suspending workers or reducing the size of the workforce due to changes in operations, lack of materials, force majeure, or accident resulting in an immediate work stoppage? 0 0% 25 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Does the employer pay workers their annual salary supplement or bonus upon termination? Does the employer provide workers proper notice of termination when required, or pay workers during the notice period? Does the employer terminate workers for reasons that are invalid under national law? Has the employer complied with any orders to reinstate or compensate workers who were found to be unjustly terminated? 2 8% 4 16% 0 0% 0 0% Four factories were found in non-compliance for not providing workers with proper notice of termination when required, or correctly paying workers during the notice period. These non-compliances are mainly related to inaccurate payment of the notice indemnity upon termination, because the calculation of the notice of termination payments for workers entitled to incentives is based on the minimum wage of reference instead of average earnings as required by the law under Article 148. The other non-compliance issues related to inaccuracy of the payments made for workers entitled to incentives, as the factories listed did not include all the wages in the calculation of the annual salary supplement or bonus and the annual leave. OCCUPATIONAL SAFETY AND HEALTH Although there is a slight decrease in the overall non-compliance rate for this cluster, the non-compliance rates for Occupational Safety and Health remain high in the Haitian garment industry (average 72%). The highest levels on noncompliance in that cluster still relate to the emergency preparedness, health services & first aid, chemicals and hazardous substances and the worker protection and working environment compliance points. … CHEMICALS AND HAZARDOUS SUBSTANCES Compliance Question # of factories found NC NC Rate by Question Are chemicals and hazardous substances properly labelled? 18 72% Are chemicals and hazardous substances properly stored? 10 20% Does the employer have chemical safety data sheets for all the hazardous chemicals used in the workplace? 21 84% 26 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Does the employer keep an inventory of chemicals and hazardous substances used in the workplace? 18 25% Does the employer provide adequate washing facilities and cleansing materials in the event of exposure to hazardous chemicals? 14 56% Has the employer effectively trained workers who work with chemicals and hazardous substances? 3 12% Has the employer taken action to assess, monitor, prevent and limit workers' exposure to chemicals and hazardous substances? 10 40% 88% of the factories assessed were found in non-compliance in the chemicals and hazardous substances compliance point. These high levels of noncompliance are due to the fact that the factories are still failing to implement sustainable systems to ensure that all chemicals and hazardous substances used in the workplace are properly managed. Better Work offered additional sessions of the seminar on chemicals management during the reporting period to address this issue. Also, it is important to note that the high level of noncompliance for chemical safety data sheets (MSDS) is often due to factories not having all the MSDS required in local language. Management is required to provide an original MSDS in French or request a proper translation. EMERGENCY PREPAREDNESS Compliance Question # of factories found NC NC Rate by Question Are emergency exits and escape routes clearly marked and posted in the workplace? 20 80% Are flammable materials safely stored? 4 16% Are possible sources of ignition appropriately safeguarded? 1 4% Are the emergency exits accessible, unobstructed and unlocked during working hours, including overtime? 13 52% Are there enough emergency exits? 1 4% Does the employer conduct periodic emergency drills? 7 28% Does the workplace have a fire detection and alarm system? 8 32% Does the workplace have adequate fire-fighting equipment? 17 68% Has the employer trained an appropriate number of workers to use the fire-fighting equipment? 7 35% 27 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Has the employer informed and prepared workers for possible emergencies in the workplace? 0 0% Most of the factories assessed have at least one non-compliance issue related to the emergency preparedness point. These high levels of non-compliance are still related to emergency exits and escape routes not clearly marked and posted in the workplace. In fact, in several factories, evacuation plans were not updated or posted. Also, the proper maintenance of the firefighting equipment is also a concern. Although Better work Haiti continues to offer training and advisory services to address these points over the years, the high turnover rate in most factories for OSH officers and OSH committee members seems to be one of the main challenges to implement sustainable OSH management systems in participating factories. Also, OSH policies are not always endorsed by senior management which another reason why regulations related to emergency preparedness are not properly enforced in the factories. In the case of obstructed exits, where systemic - rather than one off - root causes are identified, Better Work advises factories to comprehensively review workplace organization and production flows. Although a number of smaller factories contend that space limitations in their workshop(s) prevent them from fully or permanently complying with this aspect of the law. In addition, the training and advisory services provided by Better Work Haiti team, a mission with BWG OSH specialist was scheduled for the last quarter of 2018 in order to help the factories address persistent OSH issues. However, it was postponed twice due to the political unrest. WORKING TIME The working time cluster consists of three compliance points. The compliance point of leave saw a non-compliance rate of 7% over the last year, while about a fifth of factories were in non-compliance for overtime hours. The highest noncompliance point with 39% non-compliance rate was on regular hours. Further details on this point can be found below. REGULAR HOURS Compliance Question Do regular daily or weekly working hours exceed the legal limit? # of factories found NC NC Rate by Question 1 4% 28 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Does the employer comply with the daily break period? 2 8% Does the employer keep working time records that reflect the hours actually worked? 5 20% Does the employer obtain authorization from the Department of Labour before working at night? 0 0% 0 0% 0 0% 5 20% Does the employer provide required breastfeeding breaks? Does the employer give workers at least one day off after 48 hours of work? Does the employer post the factory's working hours (for all shifts, and including break times)? The highest rate of non-compliance in the area of regular working hours was due to five factories for which the assessors found inaccuracies in the working time records. In these factories, the problem was related to issues such as overtime hours or hours performed on weekly rest day not recorded were identified. Also, five factories were found in non-compliance for the question related to the paid breastfeeding break. In fact, in these factories, nursing mothers are properly informed of their right to benefits from the breastfeeding break. Their payment is not always accurate as the ones taking breastfeeding breaks in the afternoon are sometimes paid on the daily minimum wage instead of the total earnings of their sewing line for the day. 2.4. ADVISORY AND TRAINING SERVICES IN THE REPORTING PERIOD BETTER WORK ADVISORY SERVICES During the reporting period, Better Work Haiti continued its efforts to establish social dialogue mechanisms at the factory level through bipartite committees (bipartite committee). However, these committees need to be supported to become more independent and be able to meet without Better Work presence. The bipartite committee sustainability training program developed by Better Work Global was reviewed and adapted to meet the needs of the Haitian garment factories. However, one of the challenges to implement it was the changes in the bipartite committee membership. Below is an overview of each factory in the Better Work Haiti program and the status of its bipartite committee. Table 1: Factory’s BI-PARTITE COMMITTEE Status 29 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Name of factory Bipartite Committee Status 1 Caribbean Island Apparel S.A. Set up and functioning 2 Centri Group SA In progress 3 Cleveland Manufacturing S.A. (former GMC) No active bipartite committee 4 CODEVI Set up and functioning 5 Digneron Manufacturing SA In progress 6 Elansia SA In progress 7 Everest Apparel Haiti SA Set up and functioning 8 Fairway Apparel S.A. In progress 9 Go Haiti S.A. Setup in progress 10 H4H 11 H&H Textiles S.A. 12 Haiti Premier Apparel S.A. Set up and functioning 13 Hansae Haiti SA Set up and functioning 14 Horizon Manufacturing S.A. Set up and functioning 15 Silver Linings S.A. Setup in progress 16 Life S.A. Set up and functioning 17 MAS Akansyel Set up and functioning 18 MGA Haiti S.A Set up and functioning 19 Modas BU IL Haiti S.A. Set up and functioning 20 Pacific Sports Haiti S.A. Set up and functioning 21 Palm Apparel S.A. Set up and functioning 22 Premium Apparel S.A. Set up and functioning 23 Quality Sewing MFG. S.A. Set up and functioning 24 S&H Global S.A. 1 a 6 Set up and functioning 25 S&H Global S.A. 7 & Washing In progress Set up and functioning Set up and functioning 30 BETTER WORK HAITI – 18TH SYNTHESIS REPORT 26 Sewing International S.A. Set up and functioning 27 Silver Linings S.A. Set up and functioning 28 SOGEPLAST SA (Plastic company) 3 Set up and functioning 29 The Willbes Haitian II S.A. Set up and functioning 30 The Willbes Haitian III S.A. No active bipartite committee 31 The Willbes Haitian II B S.A. No active bipartite committee 32 The Willbes Haitian Print Shop S.A. No active bipartite committee 33 Val D’Or Apparel MFG Haiti S.A. Set up and functioning During the reporting period, Better Work Haiti completed 101 advisory visits including bipartite committee meetings in a total of 33 participating factories. The advisory visits were affected by the general tensions in the country as incidents of political and civil unrest occurred respectively in October and November 2018 and in February 2019. These events negatively affected the ’factories’ production and it was very difficult for EAs to confirm attendance for industry seminars and onsite advisory visits. The advisory services were tailored to each factory’s needs. However, an emphasis was made on gender issues and improving chemicals management systems. BETTER WORK TRAININGS During the reporting period 48 trainings sessions were offered to factories in Port-au-Prince, Caracol and Ouanaminthe. In an overview, the trainings offered by Better Work Haiti during the reporting period include:  Respectful Workplace Program 3 Plastic Company not exporting under HOPE II 31 BETTER WORK HAITI – 18TH SYNTHESIS REPORT  Workplace Communication  Leadership Skills  Fundamental Rights at work  Occupational Safety and Health  Training of Trainer supervisory Skills (ToT SST)  Risk Management and Control  Supervisory Skills (SST)  Chemicals` Management  Training of Trainer on Sexual Harassment  Inspection Methodology During the reporting period, the Better Work Training Team trained a total of 1724 participants – management and workers – on the above mentioned training topics, including 770 women. In addition to the funding received from USDOL, Better Work Haiti continues to use the funds from The Walt Disney Company to implement training on supervisory skills and leadership skills (Managing People). Also, funds received from the Levi Strauss Company were used to provide sexual harassment prevention training to workers as part of the new “Respectful Workplace” program. In addition to the regular training activities, Better Work Haiti organized learning events for the tripartite stakeholders. In fact during the reporting period, Better Work Haiti launched the Building Bridges academy for national partners as part of its strategy to strengthen the capacity of national stakeholders (including governments, employers and workers and their representatives) to govern their own labour markets and increasingly take on responsibilities that have shifted over the past years to the private sector, including brands. Also, as part of its new gender strategy, a workshop on women’s challenges in the workplace was organized in order to create an environment for participating organizations to convene in a joint learning process that contributes towards enhanced understanding of gender related issues. 32 BETTER WORK HAITI – 18TH SYNTHESIS REPORT As the paperless evaluation was successfully implemented in the previous reporting cycle, Better Work Haiti will now be able to use the data collected for training impact assessment. Section III: Conclusion and Next Steps Better Work Haiti’s 18th synthesis report provides a range of insights into the state of working conditions and labour standards in the garment industry today. The report draws upon data from 25 factories that were assessed from April 2018 to March 2019, bringing together quantitative compliance findings with qualitative evidence from day-to-day advisory and training work in factories. The findings have far reaching implications both for policymaking and wider industry development. As in previous years, non-compliance remains concentrated in the working conditions clusters, particularly Compensation Time and Occupational Safety and Health. In both areas, more than three-quarters of compliance points (i.e. question groupings) show non-compliance rates of more than 60 percent. Occupational safety and health has the most extensive list of questions in the Better Work assessment tool, and although there have been some observable recent improvements in this area, for example in reducing chemical exposure and hiring the required number of medical staff, consistent across-the- board progress remains difficult in many factories. A major cause of this is the lack of a systems based approach to improvement, which means that even when OSH measures are strengthened, they are often susceptible to backsliding. Having policies and procedures in place to prevent and manage OSH risks can both reduce the likelihood of human error and mitigate compliance disruptions due to high staff turnover, which remains a common concern for many factories. Better Work is actively working to introduce a systems based approach in all of its training and advisory services. BWH will continue to expand its collaboration with the Ministry of Social Affairs and Labor (MAST). A key focus will involve assisting the inspectorate to transition from a traditional enforcement model to a strategic compliance model. BWH is looking forward to engaging more extensively with the Trade Union in the coming years and 33 BETTER WORK HAITI – 18TH SYNTHESIS REPORT facilitating important skills and knowledge transfer. BWH will work closely with ACTRAV/ILO on this initiative. Going forward it is important that BWH takes its firm-level expertise and knowledge to steer and inform policy discourse and decisions. For this, the programme will put more emphasis on creating and sustaining robust relationships with national institutions as well as international organisations and Haitian’s civil society actors. Gender equality has been a key component of Better Work’s agenda. In early 2018, the programme published its ambitious five-year gender strategy to contribute to Sustainable Development Goal 5 (SDG)The strategy is built on interventions at both the national and global levels and spans across themes of discrimination, paid work and care, voice and representation, and leadership and skill development. In 2018 and beyond, aligned with the Global Strategy, BWH will increase its focus on gender and ensure gender sensitivity in its services. This will involve scaling up existing services and projects as well as working closely with national and international actors and forging new partnerships. As part of this effort, the programme will continue to explore a collaboration with UNICEF that has been a key proponent of leading discussions on day care facilities and maternity protection. Under the new country strategy BWH programme will grow its factory membership. Beyond simply enforcing compliance, this will also imply a more prominent role for the employer’s association (ADIH) in advising and training enterprises, and in promoting industry competitiveness through responsible business, in line with their organizational mandates and the wider national development agenda in Haiti. In collaboration with ACTEMP support ADIH to play a more integral part in structural reform and contributing to the national agenda with the following specific areas to address: Better understanding of Employers responsibilities’, vis –a-vis international labour standards, modernize and clarify the labor code (last revision dated 1984); Increase awareness on corporate social responsibility. 34 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Annex 1. The TAICNAR Project and Reporting Requirements under the HOPE II Legislation In 2006, the United States Congress enacted the Haitian Hemispheric Opportunity through Partnership Encouragement Act of 2006 (HOPE), expanding preferences for Haitian apparel established under the Caribbean Basin Economic Recovery Act, thus enabling the Haitian apparel industry to benefit from new duty-free preferences. In 2008, these preferences were further expanded through legislation known as HOPE II, which also established new standards and programs strengthening and monitoring working conditions in the apparel sector. On 24 May 2010, the Haiti Economic Lift Program Act of 2010 (HELP Act) was signed into law to extend existing preferences even more to contribute to Haiti’s economic growth and development in both the textile and apparel sectors. Among its provisions, the HELP Act extended almost all of the trade preferences established under HOPE and HOPE II and in 2015, the US Government extended the Haiti HELP/HOPE provisions until 2025. In order to benefit from HOPE/HOPE II/HELP, Haiti was required to establish an independent Labor Ombudsman appointed by the President of the Republic in consultation with the private sector and the trade unions. Haiti was also required to work with the ILO, to develop a technical assistance program to (i) assess and promote compliance with core labor standards and national labor law in the factories that are eligible for tariff advantages under HOPE II and (ii) provide assistance to the Government of Haiti in order to strengthen its capacity in the process of inspection of facilities. This was referred to in the legislation as the Technical Assistance Improvement and Compliance Needs Assessment and Remediation (TAICNAR) program. Finally, Haiti needed to develop a mechanism for ensuring that all producers benefiting from the HOPE II trade preferences participated in the TAICNAR program. The TAICNAR program consists of two components: TAICNAR Program Component 1: Compliance Assessments and Remediation Support The HOPE law states that the first component of the TAICNAR program is “to assess compliance by producers listed in the registry described in paragraph (2) 35 BETTER WORK HAITI – 18TH SYNTHESIS REPORT (B) (i) with the conditions set forth in subparagraph (B) and to assist such producers in meeting such conditions.” Better Work Haiti is implementing this component of the TAICNAR program. Aggregated findings for the entire industry regarding compliance with national and international labor law are outlined in section II of the report. The details of Better Work’s assessment methodology are explained in annex 3 of this reports. Annex 4 provides the details of compliance for every factory that has been assessed. It has to be noted that Better Work offers several services that go beyond the requirements of the HOPE legislation, in particular the collaboration with international brands through sharing of factory assessment reports, joint support for factories regarding the improvement plan used during advisory services (corrective action plan), specific trainings and specific projects and or events such as the annual buyers and multi-stakeholders forum. With the introduction of fees to be paid by factories for participation in the Better Work Haiti program since 2016, it has been decided that non-paying factories will receive all Better Work core services (advisory, training, and one annual assessment) in line with requirements of the HOPE legislation. Factories that do pay their subscription fee will have access to the full offer of Better Work services beyond core services only. TAICNAR Program Component 2: Technical assistance to strengthen the legal and administrative structures for improving compliance in the industry The HOPE law states that the second component of the TAICNAR program is “to provide assistance to improve the capacity of the Government of Haiti – (I) to inspect facilities of producers listed in the registry described in paragraph (2)(B)(i); and (II) to enforce labor laws and resolve labor disputes, including through measures described in subparagraph E.” The ILO has been conducting different activities under this component, mainly in the context of the USDOL-funded ILO/MAST Capacity Building project which aimed at strengthening the capacities of the Ministry in order to improve apparel factories’ compliance with international and national labor laws. The project ran from 2014 to 2017 and was closely linked to the Better Work program. As of 2018 and with Better Work`s new 5 year strategy in Haiti, the program will continue to build on the efforts of this MAST capacity building program. The revised project strategy puts stronger emphasis on the capacity building of all tripartite constituents – government, employer and worker 0rganizations – as part of the sustainability efforts of the Better Work program. With regards to the reporting requirements, the HOPE II law specifies which information needs to be included in the biannual reports to be published by the TAICNAR program. See text box below for the original text of the law. 36 BETTER WORK HAITI – 18TH SYNTHESIS REPORT SEC. 15403. LABOR OMBUDSMAN AND TECHNICAL ASSISTANCE IMPROVEMENT AND COMPLIANCE NEEDS ASSESSMENT AND REMEDIATION PROGRAM. [...] (D) BIANNUAL REPORT. —The biannual reports referred to in subparagraph (C)(i) are a report, by the entity operating the TAICNAR Program, that is published (and available to the public in a readily accessible manner) on a biannual basis, beginning 6 months after Haiti implements the TAICNAR Program under this paragraph, covering the preceding 6-month period, and that includes the following: (i) The name of each producer listed in the registry described in paragraph (2)(B)(i) that has been identified as having met the conditions under subparagraph (B). (ii) The name of each producer listed in the registry described in paragraph (2)(B)(i) that has been identified as having deficiencies with respect to the conditions under subparagraph (B), and has failed to remedy such deficiencies. (iii) For each producer listed under clause (ii) — (I) a description of the deficiencies found to exist and the specific suggestions for remediating such deficiencies made by the entity operating the TAICNAR Program; (II) a description of the efforts by the producer to remediate the deficiencies, including a description of assistance provided by any entity to assist in such remediation; and (III) with respect to deficiencies that have not been remediated, the amount of time that has elapsed since the deficiencies were first identified in a report under this subparagraph. (iv) For each producer identified as having deficiencies with respect to the conditions described under subparagraph (B) in a prior report under this subparagraph, a description of the progress made in remediating such deficiencies since the submission of the prior report, and an assessment of whether any aspect of such deficiencies persists. [...] 37 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Annex 2. Better Work’s Service Delivery Model The key principles of Better Work’s revised service model are ownership, accountability, dialogue and partnership. The core services offered to factories are advisory services, an annual assessment, and training services. Better Work’s service delivery model stresses the importance of advisory services with a stronger focus on assistance on management systems, root cause analysis and continuous learning. Better Work acknowledges the fact that auditing alone cannot contribute to sustainable remediation of noncompliances. Assessments provide a snap shot of the compliance issues, yet they do not add significant value to improvements of factories’ compliance performance. Therefore, the focus in the services that Better Work delivers to factories are on continuous learning and improvements working with factories on root causes that are underlying repeated non-compliance issues. Since 2015, a factory cycle no longer starts with an assessment on which advisory services afterwards were built in the initial approach. Under the revised Better work service delivery model, the cycle now starts with a period of approximately 100 days of advisory services in which the factory with its bipartite committee can conduct a self-diagnosis with support of its Better Work Enterprise Advisor and can work on immediate improvements where possible. The unannounced Better Work assessment is then conducted after the initial period of advisory and training services. Following the assessment, the advisory process continues, focused on enabling the bipartite committee to address issues that are listed in the improvement plan. The improvement plan includes issues that the factory has self-diagnosed and those that were identified during the Better Work assessment. Factories will be supported through tailored factory visits; issue specific seminars (on topics relevant to the country/industry) with peers from other factories; and training appropriate to the factory’s specific needs. Better Work reporting has two elements – reports completed and verified by the Better Work program and those that are completed and released directly by factories. The Better Work factory reports consist of the assessment report that is released roughly 30 days after the unannounced assessment visit. Then later on in the cycle, in the 11th month of the cycle, Better Work then publishes a progress report, detailing improvements on compliance issues, as well as infactory dialogue, continuous learning and the use of effective management 38 BETTER WORK HAITI – 18TH SYNTHESIS REPORT systems. Better Work also provides additional recommendations in this report to further strengthen the improvement process. Factories report through the Better Work portal. This portal is the platform that is also used by Better Work to share factory data with authorized international brands that subscribed to a specific factory in either of the Better Work country programs. The enhanced portal with the revised self-reporting function also offers the opportunity for factories to update their improvement plan themselves. The improvement plan lists a factory’s non-compliance points from the last Better Work independent assessment together with any other issues that the factory itself identified as areas for improvements. Once the factory updates its improvement plan online, the information is immediately available to buyers and Better Work. However, this feature has some limitations with regards to the factories’ editing rights as only Better Work can update the status of a non-compliance issue from “delayed”, “pending”, or “in progress”, to “completed” after verification of evidence of remediation. Factory reporting then continues with the first progress report which is published approximately 5 months after the start of the cycle. This report includes progress to date on all self-diagnosed issues as well as those identified by Better Work during the assessment. This report has a pre-set structure from Better Work and it is made available to authorized buyers and indicates initial progress and planned steps for the remainder of the cycle. The Better Work role for this first progress report will be limited to coaching factories on how to engage in effective self-reporting and how to ensure continued progress on closing areas of non-compliance. The Better Work Enterprise Advisors then write their own progress report towards the end of an annual cycle of each factory. An overview of the sequence of the different components of the Better Work service model under this revised approach can be found in the illustration below: 39 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Sequence and components of annual Cycle under Better Work’s revised service delivery model. In 2017, Better Work started to differentiate factories depending on their performance. Factories that are scoring high enough in terms of compliance performance but also in the areas of dialogue and learning encompass the criteria that need to be satisfied before a factory can be qualified for “stage two”. In fact, Better Work will classify factories as being in “stage two” if they consistently demonstrate high levels of compliance, a mature level of social dialogue, effective management systems and a commitment to learning. Those criteria will be evaluated based on information collected during two consecutive assessments. Factories that have not yet met this benchmark will be classified as “stage one.” For factories that have been with Better Work for several years, service differentiation will respond to requests for greater autonomy in the day to-day advisory service, fewer assessments, and a tailored service that responds to their more advanced needs, for example relating to systems development, purchasing practices, productivity and quality, and mature industrial relations. 40 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Annex 3. The Better Work Compliance Assessment Methodology BETTER WORK COMPLIANCE ASSESSMENT FRAMEWORK The Better Work program assesses factory compliance with core international labor standards and national labor law. Following assessments, a detailed report is prepared and findings are shared with the factory presenting findings on eight clusters, or categories, of labor standards, half of which are based on international standards and half on national legislation. Core labor standards: The ILO Declaration on Fundamental Principles and Rights at Work, adopted in 1998, calls upon Member States to respect and promote these principles and rights in four areas, whether or not they have ratified the relevant conventions. These categories, or clusters, are: freedom of association and collective bargaining, the elimination of forced or compulsory labor, the abolition of child labor and the elimination of discrimination in employment and occupation. The conventions on which the 1998 Declaration is based are Nos. 29, 87, 98, 105, 100, 111, 138, 182, and they form the reference base in assessing factory compliance with fundamental rights for all the Better Work programs in various countries. For some issues, such as minimum legal working age, provisions in national law specify requirements for the application of international conventions. If national law is not consistent with international standards pertaining to core labor standards, the international standards are applied. Haiti has ratified all eight core Conventions listed above. According to the Haitian Constitution, ratified conventions become self-executing and therefore part of Haitian law. Working Conditions: The four other clusters assess conditions at work, including compensation, contracts and human resources, occupational safety and health, and working time. The compliance points covered in these clusters are largely consistent across countries; however each compliance point contains specific questions that may vary from country to country due to differences in national legislation. National legislation is used as a reference point even if it is not in accordance with the international conventions that have been ratified by the country. In countries where national law either fails to address or lacks clarity around a relevant issue regarding conditions at work, Better Work establishes a benchmark based on international standards and good practices. 41 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Table 2: Better Work compliance assessment framework Compliance Cluster Child Labor Compliance Point Compliance Issue Child Labourers Documentation and Protection of Young Workers Workers under age 15 Age verification system Medical certificate, and/or an employment certificate or permit delivered by the Director of Labor provided by workers under age 18. Register of workers under age 18. Workers under age 18 working at night. Workers under age 18 working overtime. Workers under age 18 doing work that is hazardous by nature. Changing the employment status, position, wages, benefits or seniority of workers during maternity leave. Conditions of work (gender and/or marital status). Excluding maternity leave from workers’ period of continuous service Hiring (gender and/or marital status). Job announcements (gender and/or marital status). Pay (gender and/or marital status). Pregnancy tests or use of contraceptives as a condition of employment Promotion or access to training (gender and/or marital status). Sexual harassment Terminating workers or forcing them to resign if they are pregnant, on maternity leave or nursing. Termination or retirement (gender and/or marital status). Conditions of work (race, colour, origin) Harassment (race, colour, origin) Hiring (race, colour, origin) Pay (race, colour, origin) Promotion or access to training (race, colour, origin) Hazardous Work and other Worst Forms Discrimination 4 Gender Race and Origin 4 In Better Work country-specific questionnaires, a compliance point “Other Grounds” may be included under the Discrimination cluster. This category is intended to assess specific discrimination issues that are covered in national labor law, and are considered to be aligned with the objectives of the relevant ILO conventions (100 and 111), but which are not explicitly named in the conventions, e.g., age, HIV/AIDS status, disability, etc. The questionnaire for Haiti does not include the “Other Grounds” compliance point because the Haitian labor law does not identify grounds for discrimination beyond those cited in Conventions 100 and 111. 42 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Religion and Political Opinion Forced Labor Bonded Labor Coercion Forced Labor and Overtime Freedom of Association and Collective Bargaining Prison Labor Collective Bargaining Freedom to Associate Interference and Discrimination Recruitment materials (race, colour, origin) Termination or retirement (race, colour, origin) Conditions of work (religion or political opinion) Harassment (religion or political opinion) Hiring (religion or political opinion) Pay (religion or political opinion) Promotion or access to training (religion or political opinion) Recruitment materials (religion or political opinion) Termination or retirement (religion or political opinion) Debts for recruitment fees owed to the employer and/or a third party Coercive tactics. Delaying or withholding wage payments. Forced labor to discipline workers or punish them for participation in a strike Free exit from the workplace at all times, including during overtime. Freedom of movement (dormitories or industrial park). Freedom to terminate employment with reasonable notice and/or to leave their jobs when their contracts expire Threats such as deportation, cancellation of visas or reporting to the authorities Violence or the threat of violence. Workers’ access to their personal documents (such as birth certificates, passports, work permits and ID cards) Forced overtime under threat of penalty Prison labourers Access to collective bargaining agreement. Collective agreement less favourable for workers than what is required by national law. Collective bargaining/bargaining in good faith. Implementation of collective agreement. Freedom to form and/or join a union Requiring workers to join a union. Attempt(s) to interfere with, manipulate or control the union(s). Freedom to meet without management present. Incentives to refrain from joining a union or engaging in union activities. Punishment of unionists Termination or non-renewal of worker’s employment contract due to union membership or activities Threats, intimidation or harassment of unionists. 43 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Strikes Union Operations Compensation Method of Payment Minimum Wage Overtime Wages Paid Leave Premium Pay Social Security and Other Benefits Unequal treatment of multiple unions. Union membership or union activities factoring into hiring decisions Hiring of replacement workers during a strike. Preventing workers from participating in a strike. Punishing workers for participating in a strike. Security guards, the police or armed forces called on to break up a peaceful strike or arrest striking workers. Deduction of union dues upon workers’ request. Union representatives’ access to workers in the workplace. In-kind wage payments. Regular and timely payment of wages. Wage payment directly to workers at the workplace on working days Wage payment in legal currency. Correct payment of piece rate workers when their piece rate earnings exceed minimum wage. Payment of minimum wage for apprentices. Payment of minimum wage for temporary workers. Payment for ordinary overtime. Payment for overtime hours worked on holidays. Payment for overtime worked at night. Payment for overtime worked on weekly rest days. Payment for annual leave. Payment for breastfeeding breaks. Payment for legally mandated holidays. Payment for maternity leave. Payment for sick leave. Payment for weekly rest days. Payment for regular hours worked at night. Payment for regular hours worked on holidays Payment for regular working hours worked on weekly rest days Collecting and forwarding workers’ contributions for social insurance funds to ONA. Employer contribution to OFATMA for maternity and health insurance. Employer contribution to OFATMA for work-related accident insurance. Employer contribution to ONA. Forwarding of workers’ contributions to OFATMA. Payment of annual salary supplement or bonus. Deductions from workers’ wages. 44 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Wage Information, Use and Deduction Contracts and Human Resources Contracting Procedures Dialogue, Discipline and Disputes Employment Contracts Termination Occupational Safety and Health Chemicals and Hazardous Substances Emergency Preparedness Informing workers about wage payments deductions. Payroll records. Limits on the trial period for apprentices. and Bullying, harassment or humiliating treatment of workers. Disciplinary measures Resolution of grievances or disputes. Contracts for all persons performing work for the factory. Employment contracts’ compliance with the labor code, collective agreement and/or internal work rules. Internal work rules. Specifying terms and conditions of employment in written employment contracts. Workers’ understanding of the terms and conditions of employment. Annual salary supplement or bonus upon termination. Notice of termination. Orders to reinstate or compensate unjustly terminated workers. Payment for unused paid annual leave upon resignation or termination. Reasons for termination. Reductions in workforce size or suspensions due to changes in operations Assessing, monitoring, preventing and/or limiting workers’ exposure to hazardous substances. Chemical safety data sheets for all chemicals and hazardous substances in the workplace. Inventory of chemicals and hazardous substances used in the workplace. Labelling of chemicals and hazardous substances. Storage of chemicals and hazardous substances. Training workers who work with chemicals and hazardous substances. Washing facilities or cleansing materials in the event of chemical exposure. Accessible, unobstructed, and/or unlocked emergency exits during working hours, including overtime. Fire detection and alarm system. Firefighting equipment. Marking or posting of emergency exits and/or escape routes in the workplace. Number of emergency exits. Periodic emergency drills. 45 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Health Services and First Aid OSH Management Systems Welfare Facilities Worker Accommodation Worker Protection Safeguarding possible sources of ignition Storage of flammable materials Training workers to use the firefighting equipment Annual medical checks for workers. First-aid training for workers. Health checks for workers who are exposed to workrelated hazards. Medical checks for workers upon hiring. Onsite medical facilities and staff. The employer did not ensure that there were a sufficient number of readily accessible first aid boxes/supplies in the workplace. Safety and health risks to pregnant or nursing workers Assessment of general occupational safety and health issues in the factory. Legally required construction/building permits Mechanisms to ensure cooperation between workers and management on OSH matters. Recording work-related accidents and diseases and/or submitting the record to OFATMA. Written OSH policy. Certain required facilities. Eating area. Providing drinking water. Toilets. Washing facilities and/or soap. Accommodation separate from the workplace Cooking or storage facilities in the accommodation. Lighting in the accommodation. Minimum space requirements in the accommodation. Preparation for emergencies in the accommodation. Privacy in the accommodation. Protection against disease carrying animals and/or insects in the accommodation. Protection against fire in the accommodation. Protection against heat, cold and/or dampness in the accommodation. Protection against noise in the accommodation. Toilets, showers, sewage and/or garbage disposal systems in the accommodation. Ventilation in the accommodation. Water in the accommodation. Ergonomic requirements Installing guards on all dangerous moving parts of machines and equipment. 46 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Working Environment Working Time Leave Overtime Regular Hours Installing, grounding, and/or maintaining electrical wires, switches, and/or plugs. Posting safety warnings in the workplace Providing workers with personal protective clothing and equipment. Punishment of workers who removed themselves from work situations they believed presented an imminent and serious danger to life or health. Training and encouragement of workers to use PPE, machines and/or equipment safely Workplace cleanliness Workplace lighting. Workplace noise levels. Workplace temperature and/or ventilation. payment in place of annual leave Time off for annual leave. Time off for breastfeeding breaks. Time off for maternity leave. Time off for sick leave. Authorization from the Department of Labor for overtime. Authorization from the Department of Labor for work on Sundays. Limits on overtime hours worked. Voluntary overtime. Daily break periods. Regular daily and/or weekly working hours. Weekly rest period. Working time records. Authorization from the Department of Labor before working at night. CALCULATING NON-COMPLIANCE & PUBLIC REPORTING In public synthesis reports, Better Work reports on aggregated non-compliance in the participating industry as shown in Chart 1. Non-compliance is reported for each subcategory (compliance point, or “CP”) of the eight labor standards clusters. A factory is reported as non-compliant in a subcategory if it is found to be out of compliance on any issue addressed within the subcategory. With respect to the figures presented in synthesis reports, for example, a noncompliance rate of 100% means that all participating factories were found to have at least one violation in that area. The Better Work program supports fair and transparent public reporting. In all Better Work country programs, synthesis reports containing aggregated 47 BETTER WORK HAITI – 18TH SYNTHESIS REPORT information on the industry are prepared on the basis of the individual factory assessment reports and published twice a year. Better Work is currently expanding its reporting in the other Better Work countries to include individual factory-level compliance information as is already the case for Haiti. Evidence shows that public reporting of this kind helps encourage continuous improvement and reduces the probability of reversing compliance gains. Gathering and reporting these data over time enables factories to demonstrate their efforts to improve working conditions. Limitations in the Assessment Process The factory-level assessments carried out by Better Work Haiti follow a thorough checklist of about 230 questions covering the above mentioned labor standards, and gathering general information about the factory.5 Information is gathered through a variety of sources and techniques, including document review, observations on the factory floor, and interviews with managers, workers union representatives, bipartite committee members or any other relevant witness. The information collected is compiled and analysed to produce a detailed assessment report. Before the reports become official, factories are given seven calendar days to provide feedback. Worker interviews conducted during the assessment process are held onsite, either in a private room within the factory building or outside the building (yard, eating area), and take place either in small groups or individually. Interviews are conducted in Creole, the primary language of the workers. Workers may be suspicious and feel uneasy about sharing information on their workplaces with people who are not well known to them and coaching of workers by factory management is a possible issue in the industry in general. Nevertheless, after fourteen assessment cycles conducted over more than seven years, Better Work Haiti Enterprise Advisors have become more experienced at collecting information and interviewing workers, which together with other activities led by Better Work Haiti have contributed in creating an environment where workers are more comfortable discussing working conditions. Interviews with workers cover many aspects of life at work and last approximately 20 minutes. On average, 40 workers representing different sections of the factories, as well as union representatives, are interviewed. Violations in core labor standards such as sexual harassment or freedom of association are very sensitive and are more difficult to detect during factory assessments. The assessment of violation of freedom of association issues in 5 Better Work Haiti Compliance Assessment Tool (CAT) including their legal references can be accessed here: http://betterwork.org/haiti/?page_id=1731 48 BETTER WORK HAITI – 18TH SYNTHESIS REPORT the workplace is sometimes difficult to assess in a two days assessment. There are several reasons for that. One challenge is that some labor unions are organized at the sectoral level rather than at the factory level where small union cells predominate. Another challenge is that for example, the termination of unionist usually happens after a series of events. Key witnesses might have been terminated before the assessment days. Also supporting documents might not have the level of details required to determine non-compliance. Better Work is basing its assessment findings on triangulation of facts which requires sufficient evidence in order to find a factory in non-compliance on a particular compliance point and some issues are therefore not always easy to be confirmed. As more unions are present in the factories today, workers are more aware of their rights regarding freedom of association. Workers therefore are also demonstrating an increased level of openness to discuss this subject during interviews. In addition, Better Work collects information about specific cases as they are being shared by unions or other stakeholders at any given time of the year. During the assessment at a particular factory, specific questions can be asked about any case that has previously been raised and information may therefore enter the assessment report. The assessment visits usually last two days and because it is a picture of the moment, some situations that might lead to non-compliance points in the future are not reported. It is also important to keep in mind that noncompliance issues might be identified during the advisory cycle through the self-diagnosis process. Better Work supports factories in order to reinforce their capacity to conduct a self-diagnosis and to develop an improvement plan that includes points that go beyond the Better Work assessment. For all the issues included in the improvement plan, additional information is stated, such as the action to be taken and the person responsible for it within the company. All of this information in return as well as the remediation efforts are then documented in the progress reports. As Better Work is moving into a differentiated approach where services for advanced factories will be different from those for factories who still require more assistance, the evaluation of the performance of a factory will not only be limited to the assessment data but will also include information gathered in those progress reports. Another issue that may be challenging to detect during an assessment is sexual harassment which is included in Better Work Haiti’s compliance assessment tool. Similarly to other countries, it is one of the most sensitive and most difficult issues to detect during factory assessments. The assessment of sexual harassment in the workplace by Better Work Haiti is likely to underreport the extent of its occurrence. However, sexual harassment remains an issue of concern in the industry in general. As mentioned, Better Work is basing its assessment findings on triangulation of facts which requires sufficient evidence in order to find a factory in non-compliance on a particular compliance point 49 BETTER WORK HAITI – 18TH SYNTHESIS REPORT and some issues are not always easy to detect. Although concerns regarding sexual harassment persist, Better Work Haiti has seen positive developments on the topic with factories acknowledging the issue as a potential problem and demonstrating an increased openness to address it. Several factories are therefore working on prevention of sexual harassment in the workplace. In particular, Better Work’s supervisory skills training has contributed to raise awareness of this issue among supervisors in more than half of the factories in Haiti. Simple auditing of factory compliance has been widely acknowledged to be limited in rectifying compliance issues. Factories wishing to not disclose certain information are able to do so without focusing on the long-term business benefits of improving their working conditions. This is why Better Work’s approach at the factory level is much broader in its scope focusing on continuous improvements through advisory and training services, emphasizing the importance of effective systems and the involvement of workers. 50 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Annex 4: Factories in Detail LIST OF FACTORIES Below is the list of factories that have been assessed by Better Work Haiti over the past two cycles. All factories that have been assessed by Better Work more than twice are included in the data analysis and also included in the factory tables in annex 4 of this report. Please note that if an already assessed factory closed, their individual level compliance data is no longer included in this section. Table 3: List of factories in the Haitian apparel sector which have been assessed between April 2018 and March 2019 Name of factory 1 Caribbean Island Apparel S.A. 2 Centri Group SA 3 Cleveland Manufacturing S.A. (former GMC) 4 CODEVI 5 Digneron Manufacturing SA 6 Elansia SA 7 Everest Apparel Haiti SA 8 Fairway Apparel S.A. 9 Go Haiti S.A. 10 H4H 11 H&H Textiles S.A. 12 Haiti Premier Apparel S.A. 13 Hansae Haiti SA 14 Horizon Manufacturing S.A. 15 Silver Linings S.A. 16 Interamerican Wovens S.A. 51 BETTER WORK HAITI – 18TH SYNTHESIS REPORT 17 Life S.A. 18 MAS Akansyel S.A 19 MGA Haiti S.A 20 Modas BU IL Haiti S.A. 21 Pacific Sports Haiti S.A. 22 Palm Apparel S.A. 23 Premium Apparel S.A. 24 Quality Sewing MFG. S.A. 25 S&H Global 1-6 26 S&H Global Washing 7 27 Sewing International S.A. 28 Sogeplast (Plastic Company) 29 The Willbes Haitian II S.A. 30 The Willbes Haitian III S.A. 31 The Willbes Haitian II B S.A. 32 The Willbes Haitian Print Shop S.A. 33 Val D’Or Apparel MFG Haiti S.A. FINDINGS FROM THE FACTORIES This section reports on the detailed factories’ compliance performance as required by the HOPE II legislation. The HOPE II legislation requires the entity implementing the TAICNAR program (the ILO) to publish a biannual report with specific information on factories’ compliance performance. The report is supposed to cover the preceding 6-months period and should include detailed compliance information for each individual producer (see annex 1 for the exact requirements of the HOPE II legislation.), including the details of noncompliance points identified, efforts of the producer to remediate the noncompliance points as well as the time elapsed since the deficiencies have first been identified. This information is captured in the factory tables in the following section. 52 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Date of last two Better Work assessments: Caribbean Island Apparel S.A. Port-au-Prince 2840 Sep-09 Jan-19 Jan-18 Advisory and Training Services 15-Jan-19 Factory visits to Discuss Key Risk Areas for assess readiness with compliance manager. 3-Jan-19 Bipartite Committee meeting to discuss 1-Jan-19 Bipartite Committee meeting to discuss 19-Dec-18 Factory visit to Follow up on (OSH) remediation with compliance manager. 13-Dec-18 Workshop on gender with national partners. 7-Dec-18 Workshop on gender obstacles in the workplace. 1-Dec-18 PICC meeting to discuss factory working conditions. 14-Nov-18 Building Bridges Workshop 3-Oct-18 Training in Sexual Harassment Awareness and Prevention for Workers 3-Oct-18 Training in Sexual Harassment Awareness and Prevention for Supervisors & Middle Management. ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT DETAILS OF NON COMPLIANCE IMPROVEMENT PRIORITIES REMEDIATION EFFORTS MONTHS Assessment January 2019 Jan-19 Compensation Social Security and Other Benefits OFATMA contributions based on the total earnings for all workers. Ensure that OFATMA contributions are calculated on base salary which is all revenues without the payments for over time. 2 Jan-19 Contract and Human Resources Contracting Procedures Workers in the welding workshop not wearing personal protective equipment while doing welding work. Ensure workers in the welding workshop wear personal protective equipment while doing welding work including but not limited toWelding helmet, hand shield, goggles, Ear muffs. 2 53 Jan-19 Occupational Safety and Health Chemicals and Hazardous Substances Inventory does not include all chemical used in operations. Assign responsible persons for updating inventories of hazardous substances in the various locations where they are stored or used. Include all chemicals used in the workplace in the central inventory. Jan-19 Occupational Safety and Health Chemicals and Hazardous Substances Unidentified container of Gas in the welding workshop and another unidentified container of Oil found in building 13. Identify responsible person for identification of all chemical containers. Store smaller amounts of chemicals used on the floor in standard labelled containers based on recommendations from their MSDS. Include as part of weekly checks to verify compliance. 2 Jan-19 Occupational Safety and Health Chemicals and Hazardous Substances No MSDS were available for Gas, spray paint and motor finish. Identify MSDS in local language for Gas in the welding workshop, for spray paint and Moto finishing in the mechanic workshop of building 13 and post accordingly. 2 Jan-19 Occupational Safety and Health Chemicals and Hazardous Substances The use of chemicals are not isolated in building 14. Take appropriate measures to isolate use of chemicals in all buildings including possible relocation, engineering modification of the space of operation/usage. 2 Jan-19 Occupational Safety and Health Worker Protection Management has not provided earplugs for workers in cutting section of building H4 Provide adequate PPE to all workers as appropriate including but not limited to earplugs for workers in cutting section where noise exceed 90 DB. 2 Jan-19 Occupational Safety and Health Worker Protection Some chairs provided to workers in the sewing lines of all buildings were missing back rest. Remove and replace the chairs with adequate back rests 2 Management updated inventory for 2 new chemicals recently added in operations. 2 54 Jan-19 Occupational Safety and Health Worker Protection More than 50 percent of all sewing machines were missing pulley guards. Ensure that all sewing machines are have appropriate guards including but not limited to eye, finger and pulley guards. Assign a dedicated person to conduct weekly checks and to report to management. 2 Jan-19 Occupational Safety and Health Worker Protection Electrical panels are not sealed and several are mounted on wooden boxes. Ensure Entry point in all electrical panels are sealed. Ensure that no electrical panels are mounted on flammable materials. 2 Jan-19 Occupational Safety and Health Working Environment Workplace temperatures exceed 31C in all sections. Use electrical exhaust fans or cooling system/. Ensure that the air-flow to and from the fans is not blocked. Make sure that all fans are wellmaintained and regularly cleaned. Monitor workplace temperature on a regular basis 2 Jan-19 Occupational Safety and Health Working Environment Noise levels exceeded 90 DB in the cutting section. Provide earmuffs to workers of the cutting section where noise exceed 90DB. 2 Jan-19 Occupational Safety and Health Working Environment The level of lighting in the cutting section was below the 750 LUX recommendation. Provide adequate lighting to maintain cutting section at 750 LUX or more. 2 Jan-19 Occupational Safety and Health Welfare Facilities With its current workforce, the factory should have 54 functioning toilets for men and 84 functioning toilets for women. Increase the number of toilets as required by the labor code. 2 55 Jan-19 Occupational Safety and Health Emergency Preparedness 1 fire extinguisher obstructed by boxes in building 10 and 2 fire extinguishers were over charged. Assign responsible person from OSH committee to monitor accessibility and pressurization of fire extinguishers. Remind supervisors about their responsibility to enforce OSH in their area and include this in the system of daily weekly checks 2 Jan-19 Occupational Safety and Health Emergency Preparedness Escape route in the sewing line of building 14 was blocked by a trolley of fabrics. Improve induction training. Inform the supervisor about their responsibilities. Identify a space to ensure timely removal of said items after delivery of materials. Assign someone to follow-up on randomly on a weekly basis. 2 Jan-19 Occupational Safety and Health Emergency Preparedness Flammable materials such as paper were stored against electrical panel in building H3. Train workers about potential hazards and document training with dates, names and number of participants. Ensure that flammable materials are not stored near potential ignition sources. 2 Jan-19 Working Time Leave Workers were paid for 15 days of annual leave after 1 year of service but were actually only granted 12 days off. Ensure that eligible workers effectively enjoy 15 days of annual leave as legally required. Assessment October 2018 Jan-18 Occupational Safety and Health OSH Management Systems OSH policy has not been developed in consultation with worker representatives and is not signed by top management. Discuss OSH policy in bipartite committee meetings. Obtain top management signature after possible suggestions and or modifications. OSH policy was discussed in bipartite committee meetings. 56 Jan-18 Occupational Safety and Health Chemicals and Hazardous Substances No updated inventory was available for all chemicals and hazardous substances used in the workplace Assign responsible persons for updating inventories of hazardous substances in the various locations where they are stored or used. Include all chemicals used in the workplace in the central inventory. Specify who is in charge of maintaining one central inventory for the company. Jan-18 Occupational Safety and Health Chemicals and Hazardous Substances Unidentified bottles containing chemicals Define who control the chemical container upon receipt from supplier and control the label. Define who is entitled to pour chemicals in other recipients and label them. Review the MSDS to know which pictograms are needed Jan-18 Occupational Safety and Health Chemicals and Hazardous Substances No MSDSs were posted for some chemicals. Post all MSDS in the local language for all chemicals used MSDS's were posted for chemicals in use during that cycle Jan-18 Occupational Safety and Health Chemicals and Hazardous Substances No eye wash station in the spare parts department of building H4. Install and maintain a functioning eye wash in the spare parts of building H4. The eye guards were installed and a monitoring and maintenance program is in place Jan-18 Occupational Safety and Health Worker Protection 30 percent of all machines in H3 buildings were missing finger guards and pulley guards. Install and maintain finger guards and pulley guards on all sewing machines. Jan-18 Occupational Safety and Health Worker Protection Properly cover electrical box. Insulate the exposed electrical wires. Jan-18 Occupational Safety and Health Working Environment Assessors observed uncovered electrical boxes with exposed wires, uncovered electrical outlets and damaged Insulation of the electrical wires. Workplace temperatures exceed 31 C in all sections Use electrical exhaust fans or cooling system. Ensure that the air-flow to and from the fans is not blocked. Make sure that all fans are wellmaintained and regularly cleaned Chemical Inventory was updated 57 Jan-18 Occupational Safety and Health Working Environment Insufficient lighting in 1 sewing section and packing sections. Improve Lighting in 1 sewing and the packing sections. Jan-18 Occupational Safety and Health Welfare Facilities Insufficient functioning toilets for men and women. Increase the number of toilet for both sexes to meet the legal requirements. Jan-18 Occupational Safety and Health Health Services and First Aid The factory does not provide workers health checks within the first three months of hiring. Ensure that workers receive medical checks as indicated in the labor code with first 90 days. Factory provides medical checks systematically Jan-18 Occupational Safety and Health Health Services and First Aid The factory does not provide workers with annual health checks. Ensure that workers receive annual medical checks as indicated in the labor code . Factory provides medical checks systematically Jan-18 Occupational Safety and Health Health Services and First Aid There is no systematic break for pregnant women. Ensure pregnant women receive breaks as provided in the law Follow up interviews confirmed that the factory gave the additional breaks as required Jan-18 Occupational Safety and Health Health Services and First Aid Factory of this size must have a permanent onsite medical service, with at least 13 nurses and 3 doctor's visits per week. Increase the number of nurses and doctor visits to comply with labor code. Factory now counts 11 nurses as required Jan-18 Occupational Safety and Health Health Services and First Aid Training records provided revealed that workers trained in first aid is less than the 10 percent of the workforce. Plan and conduct first aid training for 10% of the worker population 10% percent of workers were trained during that cycle Jan-18 Occupational Safety and Health Emergency Preparedness Evacuation plans in building has not been updated to indicate the actual escape routes according to the recently reorganized floor layout. Update the evacuate plan to reflect actual layout of factory. The evacuation plan was updated Jan-18 Occupational Safety and Health Emergency Preparedness Flammable materials such as t-shirts were stored close to the lighting lamps. Ensure flammable materials are not stored near possible ignition sources. 58 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Date of last two Better Work assessments: Cleveland Manufacturing S.A. Port-au-Prince 1607 Nov-09 Feb-19 Jan-18 Advisory and Training Services 13-Dec-18 Training in Risk Management & Control 12-Dec-18 Factory visit to discuss about the progress made by the factory. Follow up on PICC implementation and OSH committee. Discussion about training planned and training needs. OSH factory tour. 4-Dec-18 Training of Trainer supervisory Skills (Tot SST) 1-Dec-18 Training in Chemical Management System 29-Nov-18 Factory visit to review sexual harassment policy, grievance handling mechanism and learning plan. Verify records of disciplinary measures and files of terminated workers. Discuss about the changes to be made in the OSH committee. OSH factory Tour. 17-Nov-18 Training in Sexual Harassment Awareness and Prevention Middle Management 17-Nov-18 Training in Sexual Harassment Awareness and Prevention Workers 17-Nov-18 Training in Sexual Harassment Awareness and Prevention Supervisors 29-Jun-18 Training in Chemical Management System ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT DETAILS OF NON COMPLIANCE IMPROVEMENT PRIORITIESREMEDIATION EFFORTS MONTHS Assessment Feburary 2018 Feb-19 Compensation Paid Leave The factory only paid 6 weeks for maternity leave instead of 12 weeks. Pay 12 weeks for maternity leave. 2 Feb-19 Compensation Social Security and Other Benefits The most recent ONA payment receipts reveal that the payments are not made on a monthly basis. Ensure that workers' contribution are collected and forwarded to ONA on time 26 Feb-19 Compensation Social Security and Other Benefits Late payment of employer contributions for ONA. Submit ONA payments on time and calculate this amount based on basic salary instead of the minimum wage. 26 59 Feb-19 Compensation Social Security and Other Benefits The factory has not registered with OFATMA for maternity and health insurance. Register with OFATMA for maternity and health insurance. 26 Feb-19 Compensation Social Security and Other Benefits Collecting and forwarding of workers' contributions to OFATMA for maternity and health insurance. Register with OFATMA for maternity and health insurance. Then Collect and forward workers' contributions to OFATMA. 26 Feb-19 Occupational Safety and Health Chemicals and Hazardous Substances The employer only had a list of chemicals used in the factory. 2 Feb-19 Occupational Safety and Health Chemicals and Hazardous Substances Unlabelled containers in the generators room and mechanic shop. Assign responsible persons for updating inventories of hazardous substances in the various locations where they are stored or used. Ensure that all hazardous and chemicals substances used in the workplace are properly labelled. Feb-19 Occupational Safety and Health OSH Management Systems No MSDSs were posted where chemicals are stored and used. Prepare and post MSDS where chemicals are used. 26 Feb-19 Occupational Safety and Health Chemicals and Hazardous Substances Management did not take proper action to limit and isolate the use of chemicals in all the factory. Improve maintenance of machines to reduce spots and improve isolation from chemicals. 14 Feb-19 Occupational Safety and Health Chemicals and Hazardous Substances Eyewash stations in the mezzanine floor where workers are using chemical were missing. Provide cleansing materials where chemicals are used and stored. 26 Feb-19 Occupational Safety and Health Worker Protection Workers had not been provided with masks in the stamping or Pad print section. Occupational Safety and Health Worker Protection Feb-19 The employer did not provide foot rests or shock absorbing mats near the cutting room and in the pressing section. 26 26 Provide employees with all necessary personal protective clothing and equipment according to PPE regulation. Identify area where anti fatigue mats are missing and provide anti fatigue mats for standing workers. 26 60 Feb-19 Occupational Safety and Health Worker Protection Several machines missing safety guards. Define who is in charge of installing & regularly maintaining the machine guards. Then, install the guards in accordance with the company regulation. 26 Feb-19 Occupational Safety and Health Worker Protection Electrical box, wire and outlets are not properly maintained. Properly cover electrical box; Insulate the exposed electrical wires, Make sure that the electrical outlets have been fixed. 14 Feb-19 Occupational Safety and Health Worker Protection The meeting points in case of emergency are not properly located. Identify another meeting point. 2 Feb-19 Occupational Safety and Health Working Environment Workplace temperature exceed BW recommended limit of 30 C. Ensure that the air-flow to and from the fans is not blocked. Monitor workplace temperature on a regular basis. 26 Feb-19 Occupational Safety and Health Working Environment Workplace lighting insufficient. 26 Feb-19 Occupational Safety and Health Occupational Safety and Health Welfare Facilities Insufficient number of toilets. Health Services and First Aid The factory does not provide workers health checks within the first three months of hiring. Ensure the lighting is adequate and adapted to worker's needs. Increase the number of toilets. Provide free medical heath checks for workers within the first three months of hiring. Feb-19 Occupational Safety and Health Health Services and First Aid The factory did not show evidence of annual medical checks for workers. Provide free annual checks for all workers once a year in all buildings. 26 Feb-19 Occupational Safety and Health Health Services and First Aid Insufficient medical staff. Increase the number of nurse 26 Feb-19 Occupational Safety and Health Health Services and First Aid Insufficient number of workers trained in first aid. Ensure that at least 10 percent of the workforce are trained. 26 Feb-19 26 26 61 Feb-19 Occupational Safety and Health Emergency Preparedness One fire alarm was obstructed by fabrics and other materials. Have a fire detection and alarm system suitable for the factory conditions. Remind workers that fire alarm should remain unobstructed 14 Feb-19 Occupational Safety and Health Emergency Preparedness Two fire extinguishers were not properly charged. Have someone in charge to regularly check that the fire extinguishers are properly maintained. 26 Feb-19 Occupational Safety and Health Emergency Preparedness No evacuation plan was posted on the stock floor. Evacuation plans need to be updated to accurately reflect all buildings floors. Develop and update the emergency plan. 14 Feb-19 Occupational Safety and Health Emergency Preparedness The stock floor has two doors, one is identify as exits and the other one as emergency exit. Ensure that each floor has at least 2 possible exit door. 2 Feb-19 Occupational Safety and Health Emergency Preparedness Aisles in stamping or pad print area, sewing and cutting floor were obstructed with fabrics. Identify additional space for storing goods. Remind supervisors about their responsibility to enforce OSH in their area. 2 Feb-19 Occupational Safety and Health Emergency Preparedness Fire drill not conducted every 6 months in all buildings. Conduct at least one emergency drill every six months. 14 Feb-19 Occupational Safety and Health OSH Management Systems Work-related accidents and diseases were not recorded and submitted to OFATMA for the month of May and June 2018 . Declare accidents to OFATMA 2 Feb-19 Working Time Leave The factory provided 13 days of annual leave to workers with 1 year of service instead of 15 days in 2018. Give workers the required time for annual leave. 2 Assessment January 2018 Jan-18 Compensation Paid Leave Payments for non-working holidays are based on the minimum wage instead of average earnings. Ensure that payments for non-working holidays are based average earnings. 62 Jan-18 Occupational Safety and Health Chemicals and Hazardous Substances There was no eye wash station in all areas where chemicals are stored. Install eye wash stations where chemicals are store. Eye wash stations have been installed where chemicals are used and stored. The OSH officer is in charge of the daily checks. Jan-18 Occupational Safety and Health Worker Protection Management did not provide gloves and goggles for workers in the spot cleaning area using chemicals. Provide employees with all necessary personal protective clothing and equipment according to PPE regulation. Personal protective equipment such as gloves and goggles have been provided to the workers. Jan-18 Occupational Safety and Health Worker Protection Provide anti fatigue mats for standing workers . Anti-fatigue mats have been provided to workers and additional stocks are available. Jan-18 Occupational Safety and Health Worker Protection Jan-18 Occupational Safety and Health Worker Protection Standing workers in the packing area near the cutting room were not provided with foot rests or shock absorbing mats. About 30 percent of all sewing machines were missing finger guards and pulley guards. Assessors observed 2 uncovered electrical boxes with exposed wires in the cafeteria. Moreover, in the printing building uncovered electrical outlets and electrical box were also observed near the generator room. Jan-18 Compensation Paid Leave Payments for weekly rest days are based on the minimum wage instead of average earnings. Ensure that payments for weekly rest days are based on average earnings Jan-18 Compensation Social Security and Other Benefits Employer contribution to ONA is less than 6 percent of workers' base salaries. Ensure that employer'' contribution are based on workers' base salaries then collected and forwarded to ONA on time. Payment should be submitted within the 10 business day of each month for the previous month. Install the guards in accordance with the company regulation. Insulate the exposed electrical wires, Make sure that the door of the electrical panel is closed. All electrical panels are enclosed in non combustible material. 63 Jan-18 Compensation Social Security and Other Benefits Collecting and forwarding workers' contributions for social insurance funds to ONA. Employer contribution to ONA is less than 6 percent of workers' base salaries. Ensure that employer'' contribution are based on workers' base salaries then collected and forwarded to ONA on time. Payment should be submitted within the 10 business day of each month for the previous month. Jan-18 Compensation Social Security and Other Benefits The last payment for OFATMA workrelated accident insurance was done for the previous fiscal year. Also, the amount paid by the employer to OFATMA is less than 3 percent of the workers' base salary. Pay OFATMA workrelated accident insurance for the fiscal year 20172018. Ensure that the amount declared to OFATMA match the amount received by the workers for the previous fiscal year. Jan-18 Compensation Social Security and Other Benefits Employer contribution to OFATMA for maternity and health insurance. The factory has not yet registered with OFATMA for maternity and health insurance. Jan-18 Compensation Social Security and Other Benefits Collecting and forwarding of workers' contributions to OFATMA. The factory has not yet registered with OFATMA for maternity and health insurance. Jan-18 Compensation Wage Information, Use and Deduction Jan-18 Contract and Human Resources Employment Contracts Time records of hours worked on Sundays are not entered in the payroll and are paid separately. The contracts issued in 2017 did not specify the employee's position as required by law. Register to OFATMA for maternity and health insurance. Pay the required employer contribution within the first 10 days of the months. Register to OFATMA for maternity and health insurance. Then Collect and forward workers' contributions to OFATMA within the first 10 days of the months. Include the hours worked on Sunday in the payroll Modify the contract and inform workers about their right. Payments for OFATMA work related accident have been made. Employment contract as been modified as required by the law. 64 Jan-18 Occupational Safety and Health Chemicals and Hazardous Substances Chemicals and hazardous substances such as K7M used in the spot cleaning area are not properly labelled. Define who control the chemical container upon receipt from supplier and control the label. Define who is entitled to pour chemicals in other recipients and label them. Jan-18 Occupational Safety and Health Chemicals and Hazardous Substances Chemicals and hazardous substances were not stored properly in the chemical room. Identify a storage area for chemicals. Ensure all chemicals and hazardous substances used in the factory are properly stored. Issue instruction on proper storage. New chemical warehouse is operational. All chemicals are labelled and MSDS is available and posted. Eye Wash station is installed. Jan-18 Occupational Safety and Health Chemicals and Hazardous Substances No MSDS were posted in the chemical room near the printing building where chemicals are stored. Assign a person in charge of receiving MSDS from supplier and verify that the MSDS has all the required sections. Integrate this in the purchasing procedure. Make sure to have the MSDS for all hazardous chemicals used in the workplace. Purchasing Department is responsible to collect the MSDS from the providers. All MSDS are available and translated in local language. Jan-18 Occupational Safety and Health Working Environment Workplace temperature exceed BW recommended limit of 30 C. Use electrical exhaust fans or air conditioning. Ensure that the air-flow to and from the fans is not blocked.Make sure that all fans are well-maintained and regularly cleaned Jan-18 Occupational Safety and Health Working Environment Workplace lighting insufficient. Ensure the lighting is adequate and adapted to worker's needs. Specify who is in charge of regular maintenance of the light. Conduct regular measurement & compare with BW recommended limit. 65 Jan-18 Occupational Safety and Health Welfare Facilities Insufficient number of toilets. Increase the number of toilets. Jan-18 Occupational Safety and Health Welfare Facilities Soap was not available in the AGC building and workers complained about that. Ensure that soap is always available during working hours. Jan-18 Occupational Safety and Health Health Services and First Aid The factory did not show evidence of annual medical checks for workers. Provide free annual checks for all workers once a year in all factories. Jan-18 Occupational Safety and Health Health Services and First Aid The factory did not provide health checks to workers who have been exposed to work-related hazards. Provide free annual checks for all workers exposed to work-related hazards twice a year. Jan-18 Occupational Safety and Health Health Services and First Aid The factory does not provide workers health checks within the first three months of hiring. Provide free medical health checks for workers within the first three months of hiring. Jan-18 Occupational Safety and Health Health Services and First Aid Increase the number of nurse and ensure that the factory received 3 doctor's visits per week. Jan-18 Occupational Safety and Health Health Services and First Aid The factory has 2 full time nurses. To comply with the Haitian Labour Code, a factory of this size must have a permanent onsite medical service, with at least 8 nurses and 3 doctor's visits per week. At the time of the assessment visit, the training records provided revealed that 123 out of 1548 workers were trained in first aid, which is less than the 10 percent of the workforce recommended by Better Work. Jan-18 Occupational Safety and Health Emergency Preparedness Access to 1 alarm system was obstructed by boxes in the cutting building. Furthermore, the alarm system in the printing building is not working. Ensure that all alarm system is working and they are not obstructed. Jan-18 Occupational Safety and Health Emergency Preparedness Access to 3 fire extinguishers was obstructed. Ensure that all fire extinguishers are properly maintained and are not obstructed. Soap dispenser are installed and liquid soap is available in all toilets. Ensure that trained workers regularly represent 10 percent of the workforce. Alarms are installed, working and are monitored. 66 Jan-18 Occupational Safety and Health Emergency Preparedness Insufficient number of workers trained in firefighting. Ensure that trained workers regularly represent 10 percent of the workforce. Jan-18 Occupational Safety and Health Emergency Preparedness Update the evacuation plan. Ensure that the evacuation plan is the same as the current layout. Jan-18 Occupational Safety and Health Emergency Preparedness The current evacuation plans in the cutting and fabric warehouse buildings have not been updated to indicate the actual escape routes according to the recently reorganized floor layout. Fire drill not conducted every 6 months in all buildings. Jan-18 Occupational Safety and Health Emergency Preparedness Source of ignition not properly safeguarded. Jan-18 Working Time Leave Breastfeeding break is not systematically granted. Have someone in charge of the daily inspection. Inform workers about bad practices that are prohibited in the workplace. Develop a breastfeeding break policy and inform workers and supervisors of this policy. Jan-18 Occupational Safety and Health OSH Management Systems The OSH policy has not been developed in consultation with workers and their representatives. Translate the OSH policy into the local language and ensure that the policy is signed by top management. Consult with worker representatives to make necessary adjustment in the policy. Jan-18 Occupational Safety and Health Chemicals and Hazardous Substances Management did not isolate the use of chemicals and did not install exhaust ventilation. Also, the employer does not measure exposure to occupational and environmental hazards. Set policy on maximum daily time of exposure including solution in case of overtime. Improve isolation from the chemical . Have someone in charge to plan an emergency drill every 6 months. Ensure that the drill is performed on the scheduled dates Breast feeding policy is in place and the nurses are responsible to inform workers. 67 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Date of last two Better Work assessments: CODEVI Ouanaminthe 10335 Sep-09 Feb-19 Jan-18 Advisory and Training Services 9-Nov-18 8-Nov-18 23-Oct-18 23-Oct-18 22-Oct-18 22-Oct-18 Building Bridges Workshop Factory Visit # 71- Factory tour MD, AM2, Superior with compliance officer.2- Introduction to the portal and BWH self assessment tools with new focal point Sexual Harassment Workers Sexual Harassment Workers Sexual Harassment Awareness and Prevention Middle Management Sexual Harassment Awareness and Prevention Supervisors ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT DETAILS OF NON COMPLIANCE IMPROVEMENT PRIORITIES REMEDIATION EFFORTS MONTHS Feb-19 Compensation Minimum Wages/Piece Rate Wages Sometimes workers do not receive full payment in the event of liquidity problems. Workers are not properly informed of these deductions. Feb-19 Compensation Overtime Wages Overtime payment is not accurate for some categories of personnel. Feb-19 Compensation Premium Pay Working hours completed on weekly rest days are not paid to all workers. Ensure that hours worked on Saturday are accurately paid to all eligible workers 90 Feb-19 Occupational Safety and Health Emergency Preparedness No fire detectors available in 1 of the buildings. Install fire detectors in all buildings. 30 Feb-19 Occupational Safety and Health Emergency Preparedness Several fire extinguishers were obstructed, not properly charged, not properly mounted, missing inspection tags and identification arrows. Ensure that all fire extinguishers are properly maintained and unobstructed. 30 Feb-19 Occupational Safety and Health Emergency Preparedness Post updated evacuation plans for all buildings. 102 Feb-19 Occupational Safety and Health Emergency Preparedness Evacuation plans were not updated or posted on the floor for several buildings. Aisles obstructed with fabrics in several buildings. 5 exits locked in 3 buildings. Keep all emergency exits and aisles unobstructed and easily accessible. 102 Assessment Feburary 2019 Inform workers of deductions made on their payroll Ensure that any amount deducted due to lack of small cash is paid within the next month. Ensure that overtime is accurately paid to all eligible workers 2 30 68 Feb-19 Occupational Safety and Health Emergency Preparedness Emergency drills not conducted every 6 months in all buildings. Conduct emergency drill every 6 months in all buildings. 102 Feb-19 Working Time Regular Hours Working hours including break time were not posted by the employer on the floor of several building. Post the factory's working hours including break time on the floor of all buildings. 30 Feb-19 Working Time Leave The factory did not provide at least 15 days of annual leave to all workers with one year of service. Provide at least 15 days of annual leave to all workers with one year of service. 2 Feb-19 Compensation Paid Leave Annual leave payment amount is incorrect because many elements are not included in the total earnings. Revise the procedures for annual leave to ensure that is accurately paid to all eligible workers. Communicate the new procedures to all relevant parties. 30 Feb-19 Compensation Paid Leave Sick leave payment is based on minimum wage instead of the average daily earnings. Revise the procedures for sick leave to ensure that is accurately paid to all eligible workers. Communicate the new procedures to all relevant parties. 90 Feb-19 Compensation Paid Leave The factory only paid 6 weeks for maternity leave instead of 12 weeks. Register with OFATMA for maternity and health insurance. Communicate the new procedures to all relevant parties. 90 Feb-19 Compensation Paid Leave The lunch breaks is not compensated in the payroll. Revise the payroll procedures to ensure that the daily break is accurately paid to all eligible workers. Communicate the new procedures to all relevant parties. 2 Feb-19 Compensation Social Security and Other Benefits The employer contribution to ONA is inaccurate and paid late. Revise the payment procedures to ensure that the employer contribution to ONA is paid accurately and on time. Communicate the new procedures to all relevant parties. 30 69 Feb-19 Compensation Social Security and Other Benefits Workers' contributions to ONA is inaccurate and paid late. Revise the payment procedures to ensure that the workers contribution to ONA is accurate and forwarded on time. Communicate the new procedures to all relevant parties. 30 Feb-19 Compensation Social Security and Other Benefits The annual salary supplement or bonus payment is incorrect because many elements are not included in the total earnings. Revise the procedures for annual salary supplement or bonus to ensure that is accurately paid to all eligible workers. Communicate the new procedures to all relevant parties. 30 Feb-19 Contract and Human Resources Employment Contracts The contracts of the night shift workers, do not specify the hours of work, the nature of the work or the amount of pay. Revise the contracts of the night shift workers, to specify the hours of work, the nature of the work or the salaries. Communicate the new procedures to all relevant parties. 2 Feb-19 Contract and Human Resources Contracting Procedures A review of worker contracts revealed that the apprentice contracts were not approved as legally mandated. Revise the contracts of the apprentice workers, to specify the hours of work and the salaries. Submit to MAST for approval. Communicate the new procedures to all relevant parties. 2 Feb-19 occupational Safety and Health OSH Management Systems The employer did not perform an assessment of general occupational safety and health (OSH) issues consistently across all buildings. Conduct an assessment of general occupational safety and health (OSH) issues in all buildings. Inform workers of the results of the assessment. 2 Feb-19 occupational Safety and Health OSH Management Systems The OSH Committee does not include representatives from all buildings. Implement a OSH committee with representatives from all buildings. Ensure that management and workers are equally represented. Organize monthly meetings and keep minutes. 2 Feb-19 Occupational Safety and Health OSH Management Systems CODEVI does not submit work related accidents records to OFATMA. Submit work-related accidents and diseases records to OFATMA on a monthly basis. 2 Feb-19 Occupational Safety and Health Chemicals and Hazardous Substances The employer did not provide evidence of inventory tracking for chemicals and hazardous substances used in the workplace for all the buildings in operation. Keep an updated inventory for chemicals and hazardous substances used in the workplace for all the buildings in operation 30 70 Feb-19 Occupational Safety and Health Chemicals and Hazardous Substances Several chemical spray guns with K7M in the spot cleaning sections with no labelling indicating chemical classification, hazards and safety precautions. Ensure that all chemicals and hazardous substances used in the workplace are properly labelled in local language for all the buildings. 102 Feb-19 Occupational Safety and Health Chemicals and Hazardous Substances Chemical and hazardous substances not properly stored. Ensure that all chemicals and hazardous substances used in the workplace are properly stored. 102 Feb-19 Occupational Safety and Health Chemicals and Hazardous Substances Chemical safety data sheets are not available in local language for all chemical and hazardous substances used in the workplace. 102 Feb-19 Occupational Safety and Health Chemicals and Hazardous Substances Feb-19 Occupational Safety and Health Chemicals and Hazardous Substances The employer does not take adequate measures to limit and isolate the use chemical and hazardous substances in the workplace Evidence for training of workers who work with chemicals and hazardous substances are available for only one building. Keep chemical safety data sheets for all hazardous chemicals used in the workplace. Ensure that MSDS are in local language and posted in all areas where these substances are used or stored in the workplace Limit workers 'exposure to chemicals. Ensure that chemicals are only used in adequately ventilated areas. Provide regular training for workers who work with chemicals and hazardous substances in all buildings. 2 Feb-19 Occupational Safety and Health Chemicals and Hazardous Substances Missing eyewash stations in several spot cleaning areas. Install adequate eyewash stations in all areas where Chemicals and Hazardous Substances are used. 2 Feb-19 Occupational Safety and Health Worker Protection Personal protective equipment were not provided to all eligible workers. Provide all required PPEs in all buildings. 2 Feb-19 Occupational Safety and Health Worker Protection Insufficient training for workers on proper use of personal protective equipment and machines. Provide regular training for workers on the use of PPE in all buildings. Keep adequate records. 2 Feb-19 Occupational Safety and Health Worker Protection Provide all seating working with chairs with backrest. 102 Feb-19 Occupational Safety and Health Worker Protection Several workers sitting on chairs without proper backrests in at least 4 buildings. Safety guards were missing for sewing machines. Replace all missing guards on the sewing machines. Ensure regular maintenance. 102 Feb-19 Occupational Safety and Health Worker Protection Missing hazard signs on electrical panels in 2 buildings. Install proper hazard signs on all the electrical panels. 2 Feb-19 Occupational Safety and Health Working Environment Temperature levels exceeded 30 C. Ensure that the workplace temperature is below 30 C in all buildings. 42 2 71 Feb-19 Occupational Safety and Health Working Environment Noise levels exceeded 90 Db. Ensure that the workplace noise is below 85 Db. in all buildings. 15 Feb-19 Occupational Safety and Health Working Environment Insufficient lights level in several sections. Ensure that the factory has the adequate light levels in all buildings. 2 Feb-19 Occupational Safety and Health Welfare Facilities Insufficient number of toilets. Increase the number of toilets to meet the legal requirements. 102 Feb-19 Occupational Safety and Health Welfare Facilities No soap was provided in several of the buildings and workers complain about inconsistent soap availability. Provide sufficient soap in the toilets 102 Feb-19 Occupational Safety and Health Welfare Facilities The number of seats available in the eating area is not enough to accommodate the entire workforce. Increase the eating areas available for workers. 102 Feb-19 Occupational Safety and Health Health Services and First Aid No evidence of annual medical checks to workers within the first three months of hiring were available. Provide medical checks within the first three months of hiring for all new workers 102 Feb-19 Occupational Safety and Health Health Services and First Aid No evidence of annual medical checks to workers exposed to work related hazards were available. Provide medical checks to workers exposed to work related hazards twice a year. 102 Feb-19 Occupational Safety and Health Health Services and First Aid No evidence of annual medical checks were available. Provide annual medical checks for all workers. 102 Feb-19 Occupational Safety and Health Health Services and First Aid Insufficient medical staff. Increase the number of nurses to meet the legal requirements. 102 Feb-19 Occupational Safety and Health Health Services and First Aid The total number of workers trained in first aid is less 10 percent of the workforce as recommended by Better Work. Provide first aid training to a minimum of 10 percent of the workforce 102 Jan-18 Compensation Overtime Wages Several workers categorized as apprentices do not receive compensation for the overtime hours worked. Ensure that apprentices are properly paid for all hours worked. Jan-18 Compensation Method of Payment Wage deduction should not exceed 1/6 of workers monthly earnings. Ensure that salary deductions do not exceed 1/6 of workers earnings. Assessment Jan 2018 The company revised its procedures to ensure that all employees including apprentices are paid according to the requirements of the law 72 Jan-18 Compensation Paid Leave Permanent workers were not compensated for Sunday after 6 consecutive days or 48 hours worked. Ensure that workers are compensated in line with the legal requirements. Jan-18 Compensation Paid Leave Annual leave payment is incorrect. Ensure that annual leave calculations include all the workers' earnings. Jan-18 Compensation Paid Leave Sick leave payment is incorrect. Ensure that sick leave payments are based on average workers' earnings. Jan-18 Compensation Paid Leave Maternity leave payment is incorrect. Ensure that maternity leave payments are based on average workers' earnings Jan-18 Compensation Social Security and Other Benefits Employer contribution to ONA was not paid on time. Ensure that ONA payments are accurate and on time for all buildings Jan-18 Compensation Social Security and Other Benefits Workers' contribution to ONA was not paid on time. Ensure that ONA payments are accurate and on time for all buildings Jan-18 Compensation Social Security and Other Benefits OFATMA payment for work-related accident insurance was not made for the fiscal year 2017-2018. Pay the work related accident insurance for the fiscal year 2017-2018 Jan-18 Compensation Social Security and Other Benefits The factory has not registered with OFATMA for maternity and health insurance. Register with OFATMA for maternity and health insurance Jan-18 Compensation Social Security and Other Benefits The factory has not registered with OFATMA for maternity and health insurance. Register with OFATMA for maternity and health insurance Jan-18 Compensation Social Security and Other Benefits The payment amount for the annual bonus is incorrect. Ensure that the annual bonus calculation is based on total workers earnings Jan-18 Contract and Human Resources Employment Contracts Apprentices were found to have contracts that are not approved by MAST as required by law. Ensure that the apprenticeship program is approved by MAST Jan-18 Contract and Human Resources Employment Contracts The internal work rules are not yet approved by the Ministry of Social Affairs and Labour. Follow up with MAST for the approval of internal work rules. The internal regulation and the CBA has been updated. The factory has started to provide adequate payment for sick leave to all eligible workers. The internal regulation and the CBA has been updated. The factory has started to provide adequate payment for maternity leave to all eligible workers. CODEVI paid the OFATMA until the month of September 2018. The factory posted the current version of the internal work rules in all buildings. 73 Jan-18 Occupational Safety and Health OSH Management Systems Assessment of general occupational safety and health issues was not completed in all facilities. Conduct a general occupational safety and health assessment for all buildings. CODEVI hired additional compliance officer for FW, Mazava, BrandM, MD, to conduct general OSH assessment on a regular basis. Jan-18 Occupational Safety and Health Chemicals and Hazardous Substances No inventory of chemical substances used in the workplace were provided for three facilities. Keep an accurate and updated inventory for all chemicals used in the workplace. Jan-18 Occupational Safety and Health Chemicals and Hazardous Substances Some chemicals containers did not have any kind of labelling or the labelling was in a foreign language. Ensure that all chemicals are properly labelled. Train workers and managers on proper chemical handling. All chemical containers were labelled correctly. Jan-18 Occupational Safety and Health Chemicals and Hazardous Substances Chemical storage area has not been properly built in one of the factories. Ensure that all chemicals are properly stored. Train workers and managers on proper chemical handling. The factory has ensured that all chemicals and hazardous substances used in the factory are stored properly. Jan-18 Occupational Safety and Health Chemicals and Hazardous Substances During the assessment it was observed that no MSDS were available for several chemicals substances used in the workplace. Ensure that all required MSDS are available in local language for all chemicals used in the workplace. Train workers and managers on proper chemical handling. All the missing MSDS' have been posted in the Stock room and in each station where they are using the chemicals. Jan-18 Occupational Safety and Health Chemicals and Hazardous Substances During the assessment it was observed that no eyewash stations were installed in 6 locations where chemicals are used. Install proper eye wash stations in all areas where chemicals are used in the workplace. Eye washing stations have been provided in the following area : stock room, washing stations and stamping stations. Jan-18 Occupational Safety and Health Worker Protection During the assessment it was observed that PPE were not provided to all workers exposed to hazards. Ensure that workers are provided with all required PPEs. Provide PPE training as required. Management has identified the staff in charge of providing and renewing the PPEs for each factory and updated the PPE regulation (based on MSDS and hazard inventory). All employees have been provided with the necessary personal protective clothing and equipment. Training on the proper use of PPE has also been conducted for workers. 74 Jan-18 Occupational Safety and Health Worker Protection Workers' chairs were found in poor conditions in four facilities. Provide workers with chairs with backrest. CODEVI has been gradually investing to replace the chairs at the factory and 95% of them have already been changed. Management expects to change the remaining chairs in the near future. Jan-18 Occupational Safety and Health Worker Protection Machine safety guards were missing. Ensure that all machines and equipment are equipped with the required safety guards. CODEVI defined staff in charge of maintaining machine guards for each factory and all machines have been equipped with the required safety guards. Jan-18 Occupational Safety and Health Worker Protection Exposed electrical wires and open electrical boxes with exposed wires in three facilities. Ensure that all electrical installation are properly maintained. The factory posted additional safety warnings in the noted areas. Appropriate safety warnings are posted on all plants. The factory installed dielectric carpet below the electrical panel in AM2. Jan-18 Occupational Safety and Health Worker Protection Electrical installation not properly marked. Ensure that all electrical installation are properly maintained and identified. Jan-18 Occupational Safety and Health Working Environment Temperature levels exceeded 30 C. Keep the workplace temperature below 30 C. Jan-18 Occupational Safety and Health Working Environment Noise levels exceeded 90 Db. Keep the workplace noise level below 90 Db. Jan-18 Occupational Safety and Health Welfare Facilities Insufficient number of toilets. Increase the number of toilets. Jan-18 Occupational Safety and Health Welfare Facilities Missing soap in toilets. Ensure that soap is always available during working hours. Jan-18 Occupational Safety and Health Welfare Facilities Insufficient seating in eating area. Build additional eating area for workers. The factory installed a cooling system in AM2 and Mazava. Also, more fans and heat extractors were added in FW. A cooling system will be installed in FW to reduce the temperature levels. All bathrooms are maintained clean and functional. The factory has provided adequate soap and water in all the toilets. The factory is building a modern cafeteria and kitchen for cooks. 75 Jan-18 Occupational Safety and Health Health Services and First Aid No medical checks for workers Provide free medical heath exposed to work-related hazards were checks for workers at BKI, Top provided for workers in 3 facilities. Choice and Superior within the first three months of hiring. The factory conducts medical checks for all newly hired workers and regular medical follow ups for employees performing hazardous work. All factory staff also have access to extensive medical, cardiovascular, dental, visual laboratory and operations services. Jan-18 Occupational Safety and Health Health Services and First Aid No medical checks at hiring were provided for workers in 3 facilities. Provide free annual checks for all workers exposed to workrelated hazards twice a year in all factories. The factory started to provide annual medical checks for all workers and the corresponding medical records are also available to support this. Jan-18 Occupational Safety and Health Health Services and First Aid No evidence of annual medical checks for all workers was presented. Provide free annual checks for all workers once a year in all factories. Jan-18 Occupational Safety and Health Health Services and First Aid Insufficient medical staff. Increase the number of nurses. Jan-18 Occupational Safety and Health Health Services and First Aid First aid boxes not properly equipped in some locations. Ensure that first aid boxes are available and properly supplied in all factories. Jan-18 Occupational Safety and Health Health Services and First Aid Insufficient number of workers trained Train at least 10 percent of in first aid. workforce in first aid. Jan-18 Occupational Safety and Health Emergency Preparedness No fire detectors have been installed in 3 areas and no smoke detector were installed in three others. Install adequate fire extinguishers and smoke detectors as required in all buildings. Jan-18 Occupational Safety and Health Emergency Preparedness Fire extinguishers not properly maintained. Keep all fire extinguishers properly maintained. First aid boxes were installed in all CODEVI's and Brand M buildings. Additional workers were trained in first-aid. The factory installed a sufficient number of fire extinguishers at the workplace. The maintenance service provider has also been instructed to regularly check and replace nonfunctional fire-fighting equipment. 76 Jan-18 Occupational Safety and Health Emergency Preparedness Insufficient number of workers trained Train 10 percent of the in fire fighting. workforce to use the firefighting equipment. The factory has provided firefighting training to 10% of the workforce. The employer has a calendar for the year 2018 to maintain 10% of employees trained in fire-fighting. Jan-18 Occupational Safety and Health Emergency Preparedness Escape routes not properly marked in two buildings. Mark the escape routes in all buildings. Jan-18 Occupational Safety and Health Emergency Preparedness Emergency routes and/or exits obstructed or not clearly marked in five out of seven buildings. Keep the aisles clear in all buildings. Regular inspections are conducted to ensure that all emergency exits are accessible, unobstructed and unlocked at all times. Jan-18 Occupational Safety and Health Emergency Preparedness Emergency drills not conducted every 6 months in all buildings. Conduct emergency drills for all buildings. As recommended, management is currently conducting periodic emergency drills for each factory every 6 months. MD made Emergency drills for this year Brand M made Emergency drills for this year Jan-18 Occupational Safety and Health Emergency Preparedness Cell phones were being charged inappropriately throughout the workplace near highly flammable substances. Keep all possible sources of ignition safeguarded. Provide workers with cell phone charging station. Jan-18 Working Time Regular Hours Not all hours worked on Saturday are reflected in the attendance records. Ensure that all working hours are properly recorded and compensated. Jan-18 Working Time Overtime Workers in the packing, shipping and loading session were found to have completed up to 215 hours overtime per trimester. Reduce the number of overtime hours. 77 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Date of last two Better Work assessments: Fairway Apparel S.A. Port-au-Prince 501 Mar-16 Oct-18 Aug-17 Advisory and Training Services 21-Mar-19 Advisory visit to conduct Bipartite Committee Awareness 21-Mar-19 Training on Respectful Workplace Program for Workers 14-Mar-19 Training on Respectful Workplace Program for Supervisors & Middle Management 1-Feb-19 Factory visit to discuss the Drafting of cycle 13 improvement Plan with HR director. 29-Jan-19 Training on Respectful Workplace Program 13-Dec-18 Factory visit to perform OSH tour and discuss Social Dialogue and improvement plan with plant manager. 13-Dec-18 Training on Risk Management & Control 7-Dec-18 Training on gender obstacles for women in the world of work. 4-Dec-18 Training of Trainer supervisory Skills (ToT SST) 14-Nov-18 Workshop on building bridges to overcome sectorial challenges. ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT DETAILS OF NON COMPLIANCE IMPROVEMENT PRIORITIES REMEDIATION EFFORTS All compensation for all workers are now reflected in payroll. MONTHS Assessment October 2018 Oct-18 Compensation Wage Information, Use and Deduction Payments for work performed during weekly rest day is not reflected in payroll. Ensure that recorded payroll data matches what is effectively paid to temporary workers on their payslip. 6 Oct-18 Compensation Paid Leave The factory only pays 6 weeks for maternity leave instead of 12 weeks. Complete registration process with OFATMA for maternity and health insurance so eligible workers can benefit the full 12 weeks 6 Oct-18 Compensation Social Security and Other Benefits The employer contribution to ONA is calculated on the minimum salary although the payment is made on time. Contribute 6 percent of workers' base salaries to ONA on a monthly basis within the first 10 working days of the current month as required by the code. 6 78 Oct-18 Compensation Social Security and Other Benefits The calculation for the contribution for ONA is based on the minimum salary. Contribute 6 percent of workers' base salaries to ONA on a monthly basis as required by the code. 6 Oct-18 Compensation Social Security and Other Benefits The factory is not registered with OFATMA for maternity and health insurance. Pursue registration & complete process with OFATMA for maternity and health insurance. 6 Oct-18 Compensation Social Security and Other Benefits The factory is not registered with OFATMA for maternity and health insurance. Pursue registration & complete process with OFATMA for maternity and health insurance. 6 Oct-18 Contract and Human Resources Employment Contracts 15.5% of the workforce operates on renewable temporary contract to perform work of a permanent nature with no benefits. Ensure that workers are issued contracts with benefits matching the true nature and or duration of their jobs. 6 Oct-18 Contract and Human Resources Employment Contracts 15.5% of the workforce operates on renewable temporary contract to perform work of a permanent nature with no benefits. Ensure that workers are issued contracts with benefits matching the true nature and or duration of their jobs. 6 Oct-18 Occupational Safety and Health Chemicals and Hazardous Substances The factory has an inventory of chemicals and hazardous substances used in the workplace that is incomplete. Include all chemicals used in the workplace in the central inventory 3. Specify who is in charge of maintaining one central inventory for the company. Oct-18 Occupational Safety and Health Chemicals and Hazardous Substances Assessors discovered several unidentified containers on the factory floor. Define responsibilities related to chemicals management. Review the MSDS to know which pictograms are needed. 6 Oct-18 Occupational Safety and Health Chemicals and Hazardous Substances No MSDS were available for several chemicals used at the factory. Define responsibilities related to chemicals management. The MSDS for each chemical should be available and translate in local language. 6 Oct-18 Occupational Safety and Health Chemicals and Hazardous Substances During the factory tour, assessors observed that management did not isolate the use of chemicals such as Thinner in the packing sections. Improve isolation from the chemical (e.g. separate room for spot cleaning). Limit access of other workers to the chemical workplace. 6 The factory has a responsible person to track chemical inventory. 6 79 Oct-18 Occupational Safety and Health Chemicals and Hazardous Substances Workers did not receive any training on chemicals, and training records were not available for workers using chemicals. Include & Deliver training on chemical product management to workers. 6 Oct-18 Occupational Safety and Health Chemicals and Hazardous Substances There was no eye wash station in the chemical warehouse at the time of the assessment visit. Install eye wash station in the chemical warehouse. 6 Oct-18 Occupational Safety and Health Worker Protection Management did not provide masks for workers in the packing section and proper mask for workers in the spot cleaning area. Provide appropriate PPE where it is needed for all workers including but not limited to masks for workers in the packing section and proper mask for workers in the spot cleaning area. Oct-18 Occupational Safety and Health Worker Protection Several workers were not using the safety guards installed on their machines and management did not provide evidence of training. Establish training calendar and provide more training to workers to cover at least 10% of the workforce. Oct-18 Occupational Safety and Health Worker Protection Ensure proper back rest for all chairs used on the floor. Oct-18 Occupational Safety and Health Worker Protection Assessors noticed that one chair provided to a worker in the spot cleaning area was missing back rest. It represents 33 percent of seating working in the spot cleaning section. Assessors noticed unprotected service line by steel pipe , that Entry point into the panels were not sealed and Electrical outlets were damaged. Oct-18 Occupational Safety and Health Worker Protection During the assessment visit the assessors noticed an electrical panel missing the hazard sign in the sublimation area. Ensure hazard signs are posted on all electrical panels, included but not limited to sublimation area. Oct-18 Occupational Safety and Health Working Environment Workplace temperature exceed BW recommended limit of 30 C. Ensure that the air-flow to and from the fans is not blocked. Monitor workplace temperature on a regular basis. 6 Oct-18 Occupational Safety and Health Working Environment Workplace lighting insufficient. Ensure the lighting is adequate and adapted to worker's needs. 6 The necessary personal protective equipment's were provided. 6 6 All such chairs were removed and replaced with proper back rest. 6 6 Ensure that service line cable are protected by steel pipe, that entry point into the panels are sealed, that electrical outlets are repaired or replaced to safety standards. Hazard signs were posted. 6 80 Oct-18 Occupational Safety and Health Welfare Facilities Insufficient toilets for men and women. Expand the number of toilets to the required minimum. 6 Oct-18 Occupational Safety and Health Health Services and First Aid Factory does not provide to workers free health checks within the first three months of hiring. Create a schedule to be able to monitor the health checks and take timely action on required medical checks. Management created a schedule to be able to monitor the health checks. 6 Oct-18 Occupational Safety and Health Health Services and First Aid Interviewed workers stated that the factory does not provide free health checks twice a year to workers exposed to work-related hazards. Create a schedule to be able to monitor the health checks and take timely action on required medical checks. Management created a schedule to be able to monitor the health checks. 6 Oct-18 Occupational Safety and Health Health Services and First Aid Insufficient medical personnel Have a permanent onsite medical service, with at least 3 nurses and 3 doctor's visits per week. 6 Oct-18 Occupational Safety and Health Health Services and First Aid The training records provided revealed that 11 out of 497 workers were trained in first aid, which is less than the 10 percent of the workforce recommended. Train 10% of the worker population on first aid as recommended. 6 Oct-18 Occupational Safety and Health Emergency Preparedness At the time of the assessment visit, the training records provided revealed that no training on the use of fire-fighting equipment was held during the last twelve months. Perform training on the use of fire-fighting equipment for at least 10% of the workforce. 6 Oct-18 Occupational Safety and Health Emergency Preparedness The current evacuation plans have not been updated to indicate the actual escape routes and emergency exit doors according to the recently reorganized floor layout. Updated plans to indicate the actual escape routes and emergency exit doors according to the recently reorganized floor layout. 6 Oct-18 Occupational Safety and Health Emergency Preparedness Escape routes in the fabric warehouse, cutting and packing areas were blocked by boxes of finished goods and other materials. Ensure all escape routes are not blocked 6 Oct-18 Working Time Regular Hours Pregnant workers are not allowed two additional breaks. Include the additional breaks in policy and inform workers. Additional breaks were added to the policy and workers are aware. 6 81 Oct-18 Working Time Regular Hours Management regularly punches time cards on behalf of the workers and hours worked on Sundays are recorded in an attendance sheet by the supervisor. Ensure that workers are directly accountable for effectively recording their own working time. 6 Assessment August 2017 Aug-17 Occupational Safety and Health Welfare Facilities The last drinking water test provided by the factory indicated that the water contained harmful germs. Provide workers enough free safe drinking water. Water test was completed by independent third party and revealed no germs 20 Aug-17 Occupational Safety and Health Health Services and First Aid Medical check for workers within the first three months of hiring. Ensure medical checks is provided to all workers within the first three months of hiring. Advisor verified workers hired after last audit received initial medical checks within 90 days. 20 Aug-17 Occupational Safety and Health Health Services and First Aid Health checks not performed for workers who are exposed to work-related hazards. Provide medical checks to workers who have been exposed to work related hazard twice a year. Aug-17 Occupational Safety and Health Health Services and First Aid Annual medical checks for workers. Ensure Annual medical checks is provided to all workers. Medical check is being done progressively as workers visit the clinic. So far 204 workers have been seen. 20 Aug-17 Occupational Safety and Health Health Services and First Aid Access to one first aid box was completely obstructed by fabric cartons. Ensure first aid box are accessible and remain unobstructed. All first aid boxes remained obstructed during subsequent advisory visits. 20 Aug-17 Occupational Safety and Health Emergency Preparedness The evacuation routes in fabric warehouse were obstructed by boxes of finished goods and other materials. Ensure the evacuation routes in fabric warehouse remain unobstructed during working hours, including overtime. 36 Aug-17 Compensation Minimum Wages/Piece Rate Wages The last ONA contribution is based on the minimum wage instead of the base salary. Ensure that ONA payment is based on the basic salary instead of worker's minimum wages. 83 Aug-17 Compensation Social Security and Other Benefits Collecting and forwarding worker's contributions for social insurance funds to ONA. Ensure that ONA payment is based on the basic salary instead of worker's minimum wages. 83 20 82 Aug-17 Compensation Social Security and Other Benefits The factory contributed only 2 percent of workers basic salary to OFATMA for workrelated accident insurance Ensure that the employer contribution to OFATMA for work-related accident insurance is 3 percent of workers' basic salary to OFATMA. 20 Aug-17 Compensation Social Security and Other Benefits Employer contribution to OFATMA for maternity and health insurance. Register with OFATMA for maternity and health insurance services. 20 Aug-17 Compensation Social Security and Other Benefits No Workers contributions to OFATMA for maternity and health insurance. Collect and forward workers' contributions to OFATMA for maternity and health insurance. 20 Aug-17 Contract and Human Resources Contracting Procedures Excessive overtime for non production workers. Ensure that non production worker does not exceed the legal limit of overtime hours. Management hired an extra security guard to limit the overtime. 20 Aug-17 Occupational Safety and Health OSH Management Systems The internal assessment of general occupational safety and health issues in the factory is not done. Set up an OSH committee and make a monthly assessment of general occupational safety and health in the factory. OSH committee was created and internal assessments are scheduled to take place. 20 Aug-17 Occupational Safety and Health OSH Management Systems No mechanism to ensure cooperation between workers and management on OSH matters. Ensure that the factory has an active OSH committee which meet at least once a month. OSH committee has been activated and meets every month. 20 Aug-17 Occupational Safety and Health OSH Management Systems Written OSH policy not signed by top management. Update OSH policy in consultation with workers' representatives. Ensure that the policy has been signed by top management. Policy has been signed by top management on August 3rd 2018 and discussed during OSH committee representative meeting in August. 20 Aug-17 Occupational Safety and Health Chemicals and Hazardous Substances Inventory of chemicals and hazardous substances used in the workplace does not include the amount of chemicals in storage. Update the list of chemicals used and include the products in storage in the inventory of chemicals and hazardous substances. 20 83 Aug-17 Occupational Safety and Health Chemicals and Hazardous Substances Assessing, monitoring, preventing and/or limiting workers' exposure to hazardous substances. Measure workers' exposure to hazardous substances. Management is eliminating the use of chemical products in its production 20 Aug-17 Occupational Safety and Health Chemicals and Hazardous Substances Washing facilities or cleansing materials are not available in the event of chemical exposure. Provide adequate washing facilities and cleansing materials in the event of exposure to hazardous chemicals. Aug-17 Occupational Safety and Health Worker Protection Personal protective clothing and equipment not available for workers in the spot cleaning. Replace damaged PPE and provide adequate equipment to workers using hazardous chemicals. Management provided adequate equipment to workers using hazardous chemicals 20 Aug-17 Occupational Safety and Health Worker Protection Workers are not using personal protective equipment installed on machines. Train and encourage workers to properly use personal protective equipment and machines. Training completed by top management on September 15th 58 Aug-17 Occupational Safety and Health Worker Protection Guards are not install on all dangerous parts of machines and equipment. Install proper guards and maintained on all dangerous parts of machines and equipment. Management is progressively repairing and replacing guards on the machines as needed. 20 Aug-17 Occupational Safety and Health Working Environment Workplace temperature exceed BW recommended limit of 30 C Improve the temperature levels throughout the workplace. 20 78 84 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Date of last two Better Work assessments: Go Haiti Port-au-Prince 1043 Jan-16 Oct-17 Dec-18 Advisory and Training Services 19-Mar-19 Factory visit to review employment contract and hiring procedure. Short session on progress report 1 and update improvement plan. OSH Factory tour : emergency preparedness Discuss about the implementation of the law 3*8 19-Mar-19 Meeting to present the last assessment findings and discuss about the training needs 7-Dec-18 Workshop on Gender challenges at the workplace. 1-Dec-18 Training in Chemical Management System 27-Nov-18 Training in Sexual Harassment in the events of Share Hope Factory visit to review documents such as: payment for overtime wages, notice of termination, training records, OSH policy and OSH management systems Verification of chemicals labeling, MSDS and inventory OSH factory tour: Emergency preparedness 10-Oct-18 10-Oct-18 Meeting to discuss about the expectations and the role of the committee. Also, start with the self diagnosis process. 5-May-18 Bipartite Committee (PICC/LKSB/PC) training ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT DETAILS OF NON COMPLIANCE IMPROVEMENT PRIORITIES REMEDIATION EFFORTS MONTHS Recruitment procedure has been improved, HR staff are trained on the new procedure. 3 Assessment December 2018 Dec-18 Compensation Method of Payment One worker did not receive his payroll for the past 4 weeks. Improve the recruitment procedure to ensure that all worker are registered in the HR department. Dec-18 Compensation Social Security and Other Benefits Late payment of employer contributions for ONA. Submit ONA payments on time, within the first 10 working days of each month for the previous month. 17 Dec-18 Compensation Social Security and Other Benefits The workers' contributions to ONA were overdue Ensure that workers' contribution are collected and forwarded to ONA on time within the first 10 working days of each month for the previous month. 17 85 Dec-18 Compensation Social Security and Other Benefits The payment for OFATMA maternity and health insurance is late. OFATMA payment must be done on a monthly basis, with payments for the previous month being made within the first 10 working days of the current month. 3 Dec-18 Compensation Social Security and Other Benefits The workers' contributions to OFATMA were overdue. Ensure that workers' contribution are collected and forwarded to OFATMA on time within the first 10 working days of each month for the previous month. 3 Dec-18 Contract and Human Resources Contracting Procedures Two subcontracted workers were doing welding work without proper protective equipment such as goggles or welding helmet, fire resistant clothing or insulated gloves. Provide a contract to subcontractors requiring to comply with legislation on occupational safety and health. New contract for subcontractors has been implemented and PPE are provided when needed 3 Dec-18 Occupational Safety and Health Chemicals and Hazardous Substances No MSDS were available for Clorox (Bleach) stored in the stock room. Prepare and post MSDS where chemicals are used. All MSDS have been translated in creole and are posted where chemicals are stored and used. 3 Dec-18 Occupational Safety and Health Worker Protection During the factory tour, about 40 chairs without backrest were found in the sewing area. Provide chairs with back rest for workers in the sewing section. 3 Dec-18 Occupational Safety and Health Worker Protection Assessors observed one uncovered electricity outlet without cover in the pressing area of building 38. Install cover on all electricity outlet 3 Dec-18 Occupational Safety and Health Working Environment Temperature exceed Better Work recommended limit of 30 C in all sections. Ensure that the temperature does not exceed the recommended limit. Conduct regular measurement of temperature. 28 Dec-18 Occupational Safety and Health Welfare Facilities Insufficient number of toilets. Increase the number of toilets. 28 Dec-18 Occupational Safety and Health Welfare Facilities The eating area cannot accommodate all the workers. Ensure that each facility has an eating area that can accomodate all the workers. 3 Dec-18 Occupational Safety and Health Emergency Preparedness During the assessment visit 1 fire extinguisher was obstructed and 1 was undercharged. Ensure that access to fire extinguishers remain unobstructed in the workplace. Specify who conduct daily/weekly checks 3 86 Assessment October 2017 Oct-17 Contract and Human Resources Employment Contracts Internal work rules is not approved by MAST Internal regulations should be signed by MAST and posted at the workplace. Internal regulations has been signed by MAST and posted at the workplace on 21/06/16. Oct-17 Occupational Safety and Health OSH Management Systems MSDS for adhesive glue is not available in the workplace. Post a MSDS for the adhesive glue FABRI TAC and provide training to the workers using this chemical. All MSDS has been posted and workers are trained on chemical use. Oct-17 Occupational Safety and Health Emergency Preparedness The escape routes are not clearly marked. Mark the escape routes in Building 39 properly. The escape routes have been marked properly. Oct-17 Occupational Safety and Health Emergency Preparedness Emergency light Install emergency light in the workplace. All emergency lights have been installed. Oct-17 Occupational Safety and Health Emergency Preparedness Maintenance of electrical equipment. Electrical boxes and cabinets should be regularly inspected and all switches, electrical outlets and wiring should be maintained in a good condition. Inspections are conducted on a bi-monthly basis to ensure that all electrical equipment are well maintained. Oct-17 Occupational Safety and Health Chemicals and Hazardous Substances Chemicals containers are not properly labelled. Ensure that all chemical substances are correctly labelled. Factory has labelled all chemical containers. Oct-17 Occupational Safety and Health Emergency Preparedness Several fire extinguishers obstructed in the workplace. Provide health and safety and fire safety training to all employees. Discuss OSH-related findings with managers and the OSH committee to raise their awareness and ensure their support to prevent recurrence. Workers have been trained on fire safety and OSH. Oct-17 Occupational Safety and Health Worker Protection Sewing machine operators were not using the installed eye guards. Train sewing operators to use eye guards as well as supervisors to monitor the regular use of the PPE. All sewing operators have been trained on the use of PPE. Oct-17 Working Time Overtime Overtime hours exceeded the legal limit. Monitor the amount of overtime hours worked on a weekly basis. Cross train workers and alternate when overtime is needed. The factory reduce the amount of overtime hours worked to comply with the legal limit. Oct-17 Occupational Safety and Health Working Environment Workplace temperature exceed 30 C in the following areas: Packing section, Quality section, Sewing section, pressing section Improve the temperature levels in the noted areas. 87 Oct-17 Occupational Safety and Health Working Environment Insufficient light levels. Ensure the lighting is adequate and adapted to worker's needs. All inspection tables in Building 40 have personal lighting. In addition, the factory has purchased personal sewing lamps. Oct-17 Occupational Safety and Health Welfare Facilities The factory has 6 functional toilets for 77 men and 10 functional toilets for 187 Women. Ensure that the factory has 12 functioning toilets for women. Oct-17 Occupational Safety and Health Health Services and First Aid The factory has 1 nurse and 5 doctor's visits per week. Ensure that the factory has a permanent onsite medical staff, with at least 2 nurses and 3 doctor's visits per week. The factory hired one additional nurse. Oct-17 Compensation Method of Payment Wages payment not regularly paid on time. Ensure regular and timely payment of wages every 15 days. Wages payment are done every two weeks. Oct-17 Compensation Social Security and Other Benefits Employer contribution to ONA is based on minimum wage. Ensure that ONA payment is based on the basic salary instead of worker's minimum wages. Then, made the monthly payment within the first 10 working days of the following month. Change has been done in the system and employer contributionto ONA is based on workers' basic salary. Oct-17 Compensation Social Security and Other Benefits Workers' contributions to ONA is base on the minimum wage. Ensure that ONA payment is based on the basic salary instead of worker's minimum wages. Change has been done in the system and worker's contributions to ONA is based on workers' basic salary. Oct-17 Occupational Safety and Health Worker Protection Workers are not using the eye guards on their sewing machines. Provide training to all workers and encourage them to use PPE, machines and equipment safely. Training have been provided to the operators. Oct-17 Occupational Safety and Health Worker Protection Single needle machines missing finger guards. Also the grinder in the mechanical room is missing a safety cover. Install guards on all dangerous parts of machines and equipment. Safety cover has been placed on the grinder. Oct-17 Occupational Safety and Health Health Services and First Aid First-aid training for workers. Provide first-aid training for at least 10 percent of the total workforce. First-Aid training was provided to workers. Oct-17 Occupational Safety and Health Emergency Preparedness Training workers to use the firefighting equipment. Provide training to at least 10 percent of the total workforce in the use of fire-fighting equipment. Fire-fighting training was provided to workers. 88 Oct-17 Occupational Safety and Health Emergency Preparedness Periodic emergency drill Ensure that workers participate to an emergency drill every six months. The last fire drill was done in March 2018. Oct-17 Occupational Safety and Health Emergency Preparedness Direct wire connection to electrical outlets in the storage room next to the gas thank. Ensure that possible sources of ignition appropriately safeguarded. The connection to the electrical outlet has been removed. Oct-17 Occupational Safety and Health Chemicals and Hazardous Substances Hazardous chemicals are not properly handle by workers. Ensure that hazardous chemicals such as thinner are use properly by workers. The factory is not using thinner anymore and are looking for an alternative solvent. Oct-17 Occupational Safety and Health Worker Protection lux level insufficient in the sewing lines. Encourage the use of personal lights on sewing machines and inspection tables through increased supervision. New lights have been installed on the sewing machines and inspection tables. Oct-17 Occupational Safety and Health Welfare Facilities Paper and soap are not available in the toilets all the time. Janitors should be assigned to provide soap and paper in the toilets when needed. Management may consider to increase the amount of paper and soap supplied per day. Janitors have been assigned to provide soap and paper. Oct-17 Compensation Method of Payment Payroll system. Targets should be revised to account for machine breakdowns in the modules. Targets have been revised and implemented. 89 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Date of last two Better Work assessments: H&H Textiles S.A. Port-au-Prince 2837 Jan-14 Nov-18 Nov-17 Advisory and Training Services 18-Jan-19 Meeting with management to follow up on improvement plan and progress report 1 to prepare. 7-Dec-18 Workshop on challenges of women in the workplace 4-Oct-18 Meeting with management to follow up on improvement plan. Factory tour. Meeting with PICC and OSH committee members to review OSH issues and Fire safety. ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT DETAILS OF NON COMPLIANCE IMPROVEMENT PRIORITIES REMEDIATION EFFORTS MONTHS Assessment November 2018 Nov-18 Compensation Wage Information, Use and Deduction The factory does not keep one accurate payroll register. Keep one accurate payroll. The payroll system has been revised to include cash payment on the register. The amount will be then annotated as deductions as salaries already perceived. 5 Nov-18 Compensation Social Security and Other Benefits The ONA payment for employer contribution is late. Ensure that ONA is paid on time. Management has taken measures to improve the payment system and ensure that payment for the social security is done on time. 5 Nov-18 Compensation Social Security and Other Benefits The ONA payment for workers' contribution is late. Ensure that ONA is paid on time. Management has taken measures to improve the payment system and ensure that payment for the social security is done on time. 5 Nov-18 Compensation Social Security and Other Benefits The OFATMA payment for work related accident insurance is late. Ensure that OFATMA is paid on time. OFATMA Payment has been completed for the year. 5 Nov-18 Occupational Safety and Health Chemicals and Hazardous Substances One eyewash in the first chemical storage room was not functioning properly. Make eye wash station available and functioning in all areas were chemicals are stored. A new storage area as been affected for all chemicals including paint. The new storage space has adequate eye wash station installed. 52 Nov-18 Occupational Safety and Health Worker Protection The factory did not provided proper evidence of training on the proper use of machines and personal protective equipment's. Train workers on safe use of personal protective equipment. Management has made plan for continuous training on personal protection and emergency awareness throughout the year. 5 90 Nov-18 Occupational Safety and Health Working Environment Workplace temperature was higher than 30 C. Maintain temperatures that are below 30C in the production floor. Management continuously maintain the cooling system to maintain lowest temperatures possible and keeping a comfortable working environment. 5 Nov-18 Compensation Social Security and Other Benefits The employer's contribution to OFATMA for maternity and health insurance is late. Ensure that OFATMA is paid on time. Payment for OFATMA is done on a monthly basis. Management is working on improving the system to have payment done before the 10th of every following month 5 Nov-18 Compensation Social Security and Other Benefits The employer did not forward the workers' contribution to OFATMA for maternity and health insurance on time. Ensure that OFATMA is paid on time. 5 Nov-18 Occupational Safety and Health Chemicals and Hazardous Substances The inventory provided by management did not reflect the names of all chemical substances used in the workplace. Payment for OFATMA is done on a monthly basis. Management is working on improving the system to have payment done before the 10th of every following month Update the chemical The inventory system is management procedures. Ensure updated with all the to keep one accurate and chemicals used in the updated chemical inventory. factory. Nov-18 Occupational Safety and Health Chemicals and Hazardous Substances Unlabelled chemicals found in the workplace. Update the chemical management procedures. Ensure that all chemicals are properly labelled. Train all workers using chemicals. The unlabelled containers were marked with the appropriate signs. 46 Nov-18 Occupational Safety and Health Chemicals and Hazardous Substances Several MSDS were missing for chemicals and hazardous used in the workplace. Ensure that full MSDS is available in creole in all points where chemicals are used. MSDS are posted in all areas where chemicals are posted in local language. 32 Nov-18 Occupational Safety and Health Working Environment Workplace noise levels exceeded 90 Db. Maintain noise levels below 90 dB in the production floors. Management has provided earplugs to workers in the pressing area where noise levels exceeds Better Work recommendations. 5 Nov-18 Occupational Safety and Health Welfare Facilities Insufficient number of toilets. Provide enough toilets in consideration of the ratio imposed by the national labour code. 52 Nov-18 Occupational Safety and Health Welfare Facilities Insufficient seat to accommodate the number of workers currently employed in the factory in the eating area. Provide enough seating capacity to accommodate all workers in the cafeteria and the adjacent designated eating areas. While there is no plan to install additional toilets, management ensures that all toilets are well maintained and that there's no congestion 5 40 91 Nov-18 Occupational Safety and Health Health Services and First Aid Evidence of 2 yearly medical checks for workers exposed to work related hazards was not available. Provide medical checks for workers exposed to chemicals at least twice a year. Workers exposed to chemicals will be appointed for two medical checks for the year. 21 Nov-18 Occupational Safety and Health Health Services and First Aid Evidence of systematic yearly medical checks for all workers was not available. Provide annual free medical checks for all workers Management made plan to conduct medical checks for all workers continuously throughout the year. 21 Nov-18 Occupational Safety and Health Health Services and First Aid Insufficient medical staff. Ensure there is a permanent medical staff in place according to national labour code. Management plans to recruit additional nurses to improve the medical service. 52 Nov-18 Occupational Safety and Health Health Services and First Aid Expired medicines found in the first aid box. Ensure all first aid boxes have all necessary and appropriate items to use in case of emergency. A new procedure is being implemented with a new monitoring method to ensure that all first-aid boxes are always kept up. 21 Nov-18 Occupational Safety and Health Health Services and First Aid Documentation reviewed during the assessment showed that the employer did not train any workers in first aid since 2016. Ensure at least 10% of the workforce is trained in first-aid. Management has taken measure to conduct continuous training for emergency preparedness to workers throughout the year. 5 Nov-18 Occupational Safety and Health Emergency Preparedness Fire alarm in one building malfunctioned. Ensure Fire alarm remains functional at all time. Nov-18 Occupational Safety and Health Emergency Preparedness Insufficient number of workers were trained in the use of firefighting equipment. Train at least 10% workers on the use of fire fighting equipment Training for the workers have already started. Continuous training sessions for emergency preparedness are organized throughout the year. 5 Nov-18 Occupational Safety and Health Emergency Preparedness The location of the fire extinguishers and the mezzanines were not reflected on the evacuation plan posted on the floor. Ensure all fire fighting equipment All fire fighting equipment's is properly indicated on the have been properly indicated evacuation maps. with respective locations on the evacuation maps. 21 Nov-18 Occupational Safety and Health Emergency Preparedness The emergency exit door in mezzanine in building 1 was locked. Ensure all emergency exits remain open during working hours. The layout of the mezzanine has been rearranged to improve emergency escape access and to prevent obstructions. 21 Nov-18 Working Time Regular Hours Keep one accurate attendance record including overtime hours for all workers. Ensure attendance records are accurate with actual working time. Management is implementing a new process to allow the workers to mark the actual hours worked during all working hours. This system is implemented equally during night shift and Sunday work. 21 Assessment November 2017 21 92 Nov-17 Freedom of Association and Collective Bargaining Interference and Discrimination The factory terminated 8 union leaders for absence during a sectorial strike. Reinstate terminated union leaders. The factory paid the full payment of the notice period to terminated union leaders as agreed with the union federation to close the case.. Nov-17 Contract and Human Resources Dialogue, Discipline and Disputes Incidents of verbal abuse from supervisors reported by workers and observed during the assessment visit. Train supervisors and managers on the anti-harassment and abuse policy. Nov-17 Occupational Safety and Health Chemicals and Hazardous Substances Unlabelled chemicals in use on the floor. Nov-17 Occupational Safety and Health Chemicals and Hazardous Substances Inadequate storage of chemicals and hazardous substances. Elaborate a chemicals management policy. Assign staff in charge of monitoring the chemicals storage. The factory hired two additional compliance officer. The compliance team conducts daily checks on the floors. Nov-17 Occupational Safety and Health Chemicals and Hazardous Substances Chemical safety data sheets were missing for some chemicals and hazardous substances in the workplace. Elaborate a chemicals management policy. Assign staff in charge of monitoring compliance with MSDS requirements. Post the missing MSDS. Conduct regular checks. The factory hired two additional compliance officers. The compliance team conducts daily checks on the floors. Nov-17 Occupational Safety and Health Chemicals and Hazardous Substances No washing facilities or cleansing materials in the event of chemical exposure in some areas where chemicals are used. Elaborate a chemicals management policy. Assign staff in charge of monitoring compliance with labelling requirements. Install the missing eye wash stations. Conduct regular checks. The factory hired two additional compliance officer. The compliance team conducts daily checks on the floors. Nov-17 Occupational Safety and Health Worker Protection 30 percent of the single needle machines in one building did not have finger guards. Improve the machine maintenance procedures. Assign staff in charge of monitoring availability of machine guards. Install the missing machine guards. Conduct regular checks. Missing machine guards were installed. The factory hired two additional compliance officers. The compliance team conducts daily checks on the floors to monitor the availability of machine guards. Nov-17 Occupational Safety and Health Worker Protection 7 electrical boxes in the workplace did not have any safety warning signs. Ensure that all electrical installations are properly marked. The factory marked all electrical installations. The factory hired two additional compliance officers. The compliance team conducts daily checks on the floors to monitor the availability of warning signs. The factory trained managers and supervisors on the anti-harassment and abuse policy. Elaborate a chemicals The factory hired two management policy. Assign staff additional compliance in charge of monitoring officers. The compliance team conducts daily checks compliance with labelling requirements. Conduct regular on the floors. checks. 93 Nov-17 Occupational Safety and Health Welfare Facilities Insufficient number of toilets. Increase the number of toilets. Maintain the existing ones. The factory has a maintenance plan for the existing toilets. Nov-17 Occupational Safety and Health Welfare Facilities During the factory tour, EAs observed that no soap was provided in the factory toilets. Ensure that soap is available in toilets during working hours. The factory provided soap. The compliance team conducts daily checks on the floors to monitor the availability of soap during working hours. Nov-17 Occupational Safety and Health Welfare Facilities Insufficient eating area. Increase the number of seats in the eating areas. The factory built a new eating area to accommodate all workers. Nov-17 Occupational Safety and Health Health Services and First Aid The factory did not provide health checks to workers who have been exposed to work-related hazards. Nov-17 Occupational Safety and Health Health Services and First Aid The factory did not provide annual medical checks for workers. Provide health checks to workers The factory provided the first who have been exposed to work- health checks to workers related hazards. who have been exposed to work-related hazards. A second health check will be offered but the end of the year Provide annual health checks to The factory hired two all workers. additional doctors to provide annual health checks to all workers. Nov-17 Occupational Safety and Health Health Services and First Aid Insufficient medical staff. Hire additional medical staff as required by law. The factory hired two additional doctors to provide annual health checks to all workers. Nov-17 Occupational Safety and Health Health Services and First Aid First aid boxes not properly maintained. Ensure that first aid boxes are properly supplied and easily accessible during working hours. The nurses refilled all first aid boxes as required. The compliance officers monitor the availability of first aid supplies on a daily basis. Nov-17 Occupational Safety and Health Emergency Preparedness Fire alarm systems in one building was not operational. Install fire alarm in module 4. The factory installed a fire alarm in module 4. Nov-17 Occupational Safety and Health Emergency Preparedness Firefighting equipment not properly maintained. Ensure that all fire extinguishers are properly maintained and easily accessible. The factory hired two additional compliance officer. The compliance team conducts daily checks on the floors to verify the fire extinguishers. Nov-17 Occupational Safety and Health Emergency Preparedness inadequate marking or posting of emergency exits and/or escape routes in the workplace. Ensure that evacuation plans are updated, available and displayed in all buildings. Evacuation plans was updated and displayed in module 4. Nov-17 Occupational Safety and Health Emergency Preparedness One building only had one emergency exit for the entire building. Add another exit door for Module 4 The factory added another exit for module 4 94 Nov-17 Occupational Safety and Health Emergency Preparedness Some emergency exits were not easily accessible, unobstructed, and/or unlocked during working hours, including overtime. Ensure that all exits are easily accessible during working hours. The factory added another exit for module 4 Nov-17 Occupational Safety and Health Emergency Preparedness Fire drills were not conducted every 6 months in all buildings. Conduct fire drill in all buildings every 6 months. Fire drills have been conducted on all buildings as required. Nov-17 Working Time Regular Hours Working time records reliability was not confirmed. Ensure that reasons for manual input of hours are properly recorded. 95 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Date of last two Better Work assessments: H4H S.A Port-au-Prince 470 Dec-17 Jan-18 Feb-19 Advisory and Training Services Factory visit to discuss on new layout of the premises and factory updates and concerns. 22-Feb-19 Introductory meeting with the new trade union SOTA. Presentation of Better Work cycle and services. Factory tour. 4-Feb-19 Factory visit to discuss on the improvement plan. Meeting with the OSH committee on necessary improvements for the floor. Factory tour to validate the remediation. 6-Oct-18 29-Jun-18 1-Jun-18 11-Apr-18 6-Apr-18 Occupational Safety and Health (OSH) Chemical Management System Leadership Skills Bipartite Committee (PICC/LKSB/PC) Compliance Assessment Tool Industry Seminar DETAILS OF NON COMPLIANCE IMPROVEMENT ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT Feb-19 Compensation Wage Information, Use and Deduction Hours worked on Sundays are not entered in the payroll and are paid separately. Record weekly rest in the main payroll so it could be reflected in the annual leave and annual bonus. Management is currently managing to link Sunday hours to the payroll. 15 Feb-19 Compensation Paid Leave Sick leave, maternity leave and Sunday worked were not included in the payroll. Include all revenues are included in the calculation of annual leave (weekly rest day). The correction was made in the payroll system. 15 Feb-19 Compensation Paid Leave 6 workers did not receive their maternity leave payment. Ensure to pay the maternity leave to the concerned workers. Pay on a monthly basis the OFATMA contributions for maternity and health insurance. The 6 workers were paid their maternity leave and factory is following up with OFATMA when workers are entitled to maternity leave. 15 Feb-19 Compensation Social Security and Other Benefits Late ONA payment and contributions not based on the accurate worker's base salary. Ensure that ONA contribution is on time and based on the basic salary. The ONA contribution is now based on the basis salary. 15 PRIORITIES REMEDIATION EFFORTS MONTHS Assessment Feburary 2019 96 Feb-19 Compensation Social Security and Other Benefits Late ONA payment and contributions not based on the accurate worker's base salary. Ensure that ONA contribution is on time and based on basic salary. The ONA contribution is now based on the basis salary. 15 Feb-19 Compensation Social Security and Other Benefits No evidence of payment for the fiscal year 2018-2019 were available at the time of the assessment visit. Ensure to complete the payment to OFATMA accident insurance for the fiscal year 2018-2019. The factory completed the payment for fiscal year 2018-2019. 15 Feb-19 Compensation Social Security and Other Benefits Worker's contribution to OFATMA are late and based on minimum wage. Ensure to forward workers 'contributions calculated on worker's basis salary to OFATMA maternity and health contributions on a monthly basis within the first 10 days of the following month. The payment is now based on the basic salary. 15 Feb-19 Compensation Social Security and Other Benefits Employers' contributions to OFATMA were consistently late and based on the minimum salary. Ensure to forward the employer's contributions calculated on worker's base salary to OFATMA maternity and health contributions on a monthly basis within the first 10 days of the following month. Employer's contribution to OFATMA is based on the worker's basic salary. 15 Feb-19 Compensation Social Security and Other Benefits Sick leave, maternity leave and payments for Sundays worked were not included in the total annual earnings. Include all earnings in the calculation of the yearly average earnings. Management is setting the payroll system to include all earnings in the calculation of bonus 15 Feb-19 Occupational Safety and Health OSH Management Systems The employer did not consult with the workers in doing the assessment and inform them about the results. Share the internal assessment with the OSH committee. Feb-19 Occupational Safety and Health OSH Management Systems Submission of accidents report was inconsistent. Submit accident records on a monthly basis Feb-19 Occupational Safety and Health Chemicals and Hazardous Substances The chemical inventory does not include the locations of storage. Designate specific location appropriate for chemicals and hazardous substances. 15 The factory submits accident record to OFATMA on a monthly basis. 15 15 97 The management identified all chemicals used in the factory. The OSH officer is in charge to monitor chemical handling. 15 Feb-19 Occupational Safety and Health Chemicals and Hazardous Substances Unidentified containers of oil were found in the mechanic shop. Label all containers used in the workplace. Assign accountability to OSH officers ad OSH committee on that matter. Feb-19 Occupational Safety and Health Chemicals and Hazardous Substances No MSDS were available for chemicals such as paints , electrolyte, Carb and choke cleaner, pull out and oil in the mechanic workshop. Ensure that MSDS are available for all chemical used in the workplace. 15 Feb-19 Occupational Safety and Health Chemicals and Hazardous Substances Documented evidence of actions taken by management to control and oversee workers' exposure to chemicals and hazardous substances were unavailable during the assessment. Set policy on maximum daily of exposure. Limit access of the other workers in area where chemicals are used or manipulated. Provide ventilation system in such area. 15 Feb-19 Occupational Safety and Health Chemicals and Hazardous Substances No eye wash station was available where chemicals are used and stored. Provide eye wash facility where chemicals are used. 15 Feb-19 Occupational Safety and Health Worker Protection Factory did not provide earplugs for workers in the generator rooms. Also safety belt and safety cap for workers in the fabric warehouse. Provide earplugs to workers in the generators rooms and safety belt and cap for workers in the fabrics warehouse. Earplug is provided for workers in the generator room. Safety cap and safety are provided to workers in the warehouse section. A training on PPE is scheduled for April. 15 Feb-19 Occupational Safety and Health Worker Protection Electrical panels near the bathrooms were not sealed and exposed wire the plotting area. Properly maintain electrical equipment. Entry point into the electrical panel near the bathroom are sealed. The chief electrician is in charge to regularly check the electrical equipment. 15 Feb-19 Occupational Safety and Health Worker Protection One electrical panel missing the hazard sign in the generator room. Post hazard signs on electrical panel 15 Feb-19 Occupational Safety and Health Working Environment Temperature level exceeded 30 C. Ensure that the temperature level is monitored at 30 C. 15 Feb-19 Occupational Safety and Health Working Environment Light levels were inadequate in cutting and packing sections. Ensure that light is acceptable and follow the lux requirements. 15 98 Feb-19 Occupational Safety and Health Welfare Facilities Insufficient number of toilets. Ensure that the number of toilet is compliant regarding the workforce. The factory has now 24 toilets for women and plans men's toilets into women's toilets to be compliant. 15 Feb-19 Occupational Safety and Health Health Services and First Aid No documentation showing systematic health checks for workers exposed to work related hazards was available. Facilitate systematic health checks for workers exposed to work related accident. Factory already paid for the CDS (health cards) and is following up with OFATMA to have the medical checks done. 15 Feb-19 Occupational Safety and Health Health Services and First Aid No documentation was provided showing systematic health checks of workers. Facilitate systematic health checks for workers. Factory already paid for the CDS (health cards) and is following up with OFATMA to have the medical checks done. 15 Feb-19 Occupational Safety and Health Health Services and First Aid Less than 10 per cent of the workforce trained in first Aid. Train 10 percent of the workforce in first aid. A training with the fire fighters is scheduled for the end of April 2019. 15 Feb-19 Occupational Safety and Health Emergency Preparedness Fire extinguishers missing in the designated location and one fire extinguisher overcharged. Properly maintain fire safety equipment. Fire extinguishers are inspected on a daily basis and a proper maintenance is made on a monthly basis. 15 Feb-19 Occupational Safety and Health Emergency Preparedness Evacuation plans does not include the locations of fire extinguishers. In addition, the recently reorganized floor layout is not clearly marked. Update accordingly the layout with the evacuation plan in including the meeting point. Mark the floor layout. Feb-19 Occupational Safety and Health Emergency Preparedness Evidence were available only for one emergency drill within a year. Performed 1 drill every 6 months. The factory scheduled a drill with the fire fighters for the end of April 2019. 15 Assessment Janurary 2018 Jan-18 Occupational Safety and Health Documentation and Protection of Young Workers Several workers' file found without a government-issued CIN Card (National Identification Card). Ensure to have the National Identification Card prior recruiting any worker. All workers' files have a one visible copy of the national ID card (CIN). Jan-18 Occupational Safety and Health Social Security and Other Benefits The factory did not yet register with OFATMA for work-related accident insurance. Register with OFATMA for work-related accident insurance The factory is registered with OFATMA for workrelated accident insurance. The payment was finalized in March 2018. 15 99 Jan-18 Occupational Safety and Health Social Security and Other Benefits The factory did not yet register with OFATMA for maternity and health insurance. Register with OFATMA for maternity and health insurance The factory is registered with OFATMA for maternity and health insurance. Jan-18 Occupational Safety and Health Social Security and Other Benefits The factory did not yet register with OFATMA for maternity and health insurance. Register with OFATMA for maternity and health insurance The factory is register for OFATMA for maternity and health insurance. Jan-18 Contract and Human Resources Contracting Procedures No systematic medical checks were arranged for non-production workers who have been exposed to work related hazards. Arrange, at least, two medical checks for workers who been exposed to work related hazards. All medical checks for workers including newly recruited workers in their first three months of hiring were completed. All the workers have a medical file. Jan-18 Contract and Human Resources Termination No evidence for payment of unused annual leave upon resignation or termination. Pay their statutory dues to terminated workers The factory pays their statutory dues to terminated workers. Jan-18 Occupational Safety and Health OSH Management Systems No self-assessment records were available. Perform assessment on general occupational health and safety issues in the factory. Keep regular meeting with OSH committee members. General occupational health and safety assessments are done on a monthly basis by the OSH officer. Jan-18 Occupational Safety and Health OSH Management Systems No written OSH policy was available. Set up the OSH committee and plan regular meetings to address OSH concerns The OSH committee is formed. Meetings are held on a monthly basis. Jan-18 Occupational Safety and Health OSH Management Systems The records of work-related accidents are not submitted to OFATMA on a monthly basis as the factory is not yet registered with OFATMA. Submit on a monthly basis work-related accidents records to OFATMA The factory is recorded the work-related accidents and submit the records to OFATMA on a monthly basis. Jan-18 Occupational Safety and Health OSH Management Systems As per management interview, there is no written OSH policy signed by top management. OSH policy to be signed by top management OSH policy is signed by top management Jan-18 Occupational Safety and Health Worker Protection Management has provided proper metal gloves for workers in the cutting department, gloves and goggles for workers in the mechanic shop. Provide all required personal protective equipment to workers in the mechanic shop The factory has provided required personal protective equipment to workers in the mechanic area. Jan-18 Occupational Safety and Health Worker Protection No standing mats were available for workers in the packing section. Provide standing mats in the packing section The factory has provided standing mats for workers in the packing section. 100 Jan-18 Occupational Safety and Health Worker Protection One uncovered electric box and one another box that was obstructed by chairs. Ensure all electric boxes are covered and unobstructed The factory ensures that all electric boxes are covered and unobstructed. Jan-18 Occupational Safety and Health Health Services and First Aid Workers did not receive any medical checks within the first three months of hiring. Facilitate a medical for workers within the first months of hiring. All medical checks for workers including newly recruited workers in their first three months of hiring were completed. All the workers have a medical file. Jan-18 Occupational Safety and Health Health Services and First Aid Insufficient medical staff. Comply with legal requirements regarding the medical staff The factory has 2 nurses and 3 times doctor's visits. Jan-18 Occupational Safety and Health Health Services and First Aid Less than10 per cent of the workforce trained in first aid training. Train 10% of the workforce in first aid 33 additional workers were trained in first-aid on June 2018. Jan-18 Occupational Safety and Health Emergency Preparedness One fire extinguisher found undercharged. Ensure the fie-fighting equipment are properly maintained. The fire-fighting equipment are properly maintained, on a monthly basis, by a service provider. Jan-18 Occupational Safety and Health Emergency Preparedness Less than 10 percent of the workforce trained in fire fighting. Train 10% of the workforce in fire-safety. 33 more workers were trained to use the firefighting equipment. 101 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Date of last two Better Work assessments: Haiti Premier Apparel S.A Port-au-Prince 1228 Aug-10 Nov-18 Sep-17 Advisory and Training Services 26-Mar-19 Factory visit to discuss the improvement plan and remediation made. Discussion with trade union leaders on main concerns faced inside the facility and proposed solutions. Factory tour wish OSH committee members and debrief to validate the remediation. 26-Mar-19 Meeting to present the annual training calendar. Discussion was also about the drop in orders. 24-Oct-18 Factory visit to discuss on the Improvement plan. Meeting with trade unions representative on the social dialogue inside the facility. Factory tour to validate the OSH remediation. 24-Oct-18 Meeting to present a problem solved activity. Discussion was also about social benefits. 29-Jun-18 Training in Chemical Management System 6-Apr-18 Industry Seminar on the Compliance Assessment Tool (CAT) ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT DETAILS OF NON COMPLIANCE IMPROVEMENT PRIORITIES REMEDIATION EFFORTS MONTHS Nov-18 Compensation Paid Leave Weekly rest days are paid on minimum wage instead of the average earning. Pay weekly rest days based on average earnings. 22 Nov-18 Compensation Paid Leave Workers only receive 6 weeks of maternity leave instead of 12 weeks. Register in the mandatory maternity insurance system offered through OFATMA. 6 Nov-18 Compensation Paid Leave Breastfeeding break are not paid on Saturday and holidays. Ensure the nursing women are allowed to take the break. Pay accordingly the time off. Nov-18 Compensation Social Security and Other Benefits The factory calculates ONA employer's contribution based on minimum wage instead of base salary. Late payment. Pay within the first 10 business days of the next month for the previous month. Calculate the contribution based on base salary. 28 Nov-18 Compensation Social Security and Other Benefits The factory calculates ONA workers' contribution based on minimum wage instead of base salary. Late payment. Pay within the first 10 business days of the next month for the previous month. Calculate the contribution based on base salary. 28 Nov-18 Compensation Social Security and Other Benefits A the time of the assessment visit the invoice for 2017-2018 fiscal year was not yet fully paid. Management said that they were processing the payment for the remaining balance. Pay the full amount of OFATMA for work related accident for the fiscal year 2017-2018. Assessment April 2018 The factory pays for breastfeeding break to nursing mothers. In January a session was organized with supervisor on factory's breastfeeding policy. Factory completed the payment for fiscal year 20172018 for OFATMA work related accident. The factory completed 1/3 of the payment for fiscal year 2018-2019. 6 28 102 Nov-18 Compensation Social Security and Other Benefits The factory has not registered with OFATMA for maternity and health insurance. Therefore, factory did not pay employer's contribution to OFATMA. Register with OFATMA for maternity and health insurance. Pay employer's contribution to OFATMA. 28 Nov-18 Compensation Social Security and Other Benefits The factory has not registered with OFATMA for maternity and health insurance. Therefore, factory did not collect and forward worker's contribution to OFATMA. Register with OFATMA for maternity and health insurance. Collect and forward workers' contribution to OFATMA. 28 Nov-18 Occupational Safety and Health Chemicals and Hazardous Substances The chemical inventory does not specify the quantity in stock and location. Specify the quantity and storage area in the inventory. Ensure that responsibilities are assigned for chemical handling. 6 Nov-18 Occupational Safety and Health Worker Protection Ensure that all sewing machines have safety guards. Establish checklists to ensure to that all the machines have their necessary guards. Ensure that responsibilities are assigned for machine maintenance. 28 Nov-18 Occupational Safety and Health Worker Protection Several exposed electrical wires observed in both buildings. Ensure that electrical equipment are properly installed and well maintained. Ensure that responsibilities are assigned for electrical maintenance. 17 Nov-18 Occupational Safety and Health Working Environment Temperature levels exceeded 30 C in all sections. Keep the temperature level to keep under 30 C inside the workplace. 28 Nov-18 Occupational Safety and Health Working Environment Light levels were inadequate in sewing section 472 Lux where the recommended level is 500 Lux. Ensure to keep the light levels acceptable in the sewing department. 28 Nov-18 Occupational Safety and Health Welfare Facilities Insufficient number of toilets. Add more toilets, 9 for men and 35 for women. 28 Nov-18 Occupational Safety and Health Health Services and First Aid No medical checks provided to workers exposed to work-related hazards. 28 Nov-18 Occupational Safety and Health Health Services and First Aid No annual medical checks provided to workers. Arrange medical checks twice a year for workers exposed to workrelated hazards. Arrange at least one annual medical check for workers. Nov-18 Occupational Safety and Health Occupational Safety and Health Health Services and First Aid Health Services and First Aid Insufficient medical staff. Hire 5 more nurses. 28 Less than 10 per cent of the workforce trained in first aid. Train 10 percent of the workforce in first-Aid training. 28 Nov-18 28 103 Nov-18 Occupational Safety and Health Emergency Preparedness Two fire extinguishers were found overcharged. Ensure that the fire extinguishers are properly maintained. The fire extinguishers are regularly maintained on a monthly basis by external provider with expertise on the matter. The officer is in charge to perform daily check on fire safety equipment including the fire extinguishers. 28 Nov-18 Occupational Safety and Health Emergency Preparedness Les than 10 per cent of the workforce trained in fire fighting. Train 10 percent of the workforce in fire-fighting. 6 Nov-18 Occupational Safety and Health Emergency Preparedness Evacuation lines were not properly marked in building 2. Properly mark escape routes where necessary. Ensure that responsibilities are assigned for the evacuation plan. 6 Nov-18 Working Time Regular Hours Working hours are not posted on the factory floor. Post the working hours to be easily visible to the workers. 6 Nov-18 Working Time Leave Breastfeeding women are not allowed to Provide 1 hour break to HR had a meeting with 1 hour additional break during working breastfeeding workers as per as the supervisors on the matter to time on Saturdays and holydays. internal breastfeeding policy. enforce the policy. Properly inform all supervisor of the policy and monitor its application. Post the policy in the floor so all workers could see it. 6 Assessment July 2018 Jul-17 Compensation Paid Leave Payment for legally mandated holidays is based on the minimum wage instead of the worker's average earnings. Ensure the payment for legally mandate holidays accurately. Jul-17 Compensation Paid Leave The payment for weekly rest days is based on the minimum wage instead of the worker's average earnings. Pay weekly rest day accurately. 22 Jul-17 Compensation Social Security and Other Benefits Pay ONA's deductions on time and based on 6 per cent worker's basis salary and on time. 22 Jul-17 Compensation Social Security and Other Benefits The amount paid by the employer to ONA is late and less than the legally prescribed 6 percent of the workers' base salary. The workers' contribution to ONA is late and less than the legally prescribed 6 percent of the workers' base salary. Pay ONA's deductions on time and based on 6 per cent worker's basis salary and on time. 22 Jul-17 Compensation Social Security and Other Benefits The amount paid by the employer to OFATMA for work-related accident insurance is less than 3 percent of the workers' base salary. Pay OFATMA's contributions for work-related accident accurately on time and based on 3 per cent of workers' base salary. 22 Jul-17 Compensation Social Security and Other Benefits The factory has not yet registered with OFATMA for maternity and health insurance. Register with OFATMA for maternity and health insurance. 22 Legally holidays are paid based on the workers' average earnings. 22 104 Jul-17 Compensation Social Security and Other Benefits The factory has not yet registered with OFATMA for maternity and health insurance. Register with OFATMA for maternity and health insurance. 22 Jul-17 Occupational Safety and Health OSH Management Systems OSH policy does not include establishing measurable objectives and improvement targets and is not developed through consultation with workers and their representatives. Ensure to Have an adequately written OSH policy. 11 Jul-17 Occupational Safety and Health Chemicals and Hazardous Substances Chemicals are labelled in a foreign language. Label all the chemicals and hazardous substances accordingly and in the local language. The factory hired a new compliance officer to reinforce OSH compliance. 22 Jul-17 Occupational Safety and Health Chemicals and Hazardous Substances Provide MSDS' for all chemical substances used in the workplace. MSDS were available in the spot cleaning area 22 Jul-17 Occupational Safety and Health Worker Protection Jul-17 Occupational Safety and Health Worker Protection The MSDS' were not available for KM7, Blow Out and Pull Out in the spot cleaning area. The factory has not provided goggles and impervious aprons for the chemical warehouse workers and the face masks provided were in poor condition. Workers in the embroidery area were not using the provided earplugs to protect themselves from the high level of noise in the section. Jul-17 Occupational Safety and Health Worker Protection Jul-17 Occupational Safety and Health Worker Protection Jul-17 Occupational Safety and Health Working Environment Jul-17 Occupational Safety and Health Working Environment Jul-17 Occupational Safety and Health Jul-17 Shock absorbing mats were not provided to most workers in the inspection areas of the different modules. 70 percent of the sewing machines did not have belt and eye guards and another machine located in the cutting area did not have a pulley guard. The temperature level exceeded the recommended 30 C in all sections. Ensure to give appropriate protective equipment to workers. 11 Provide earplugs to workers in the embroidery area. 11 Provide absorbing mats or foot rest The factory hired a new to standing workers. compliance officer to reinforce OSH compliance. 22 Ensure that all machines have their appropriate guards. 22 The factory hired a new compliance officer to reinforce OSH compliance. Ensure that temperature is under 30C. 22 The light level was inadequate in the sewing section 413 Lux where the recommended level is 500 Lux. Ensure the workplace is adequately lit. 22 Welfare Facilities Insufficient number of toilets. Have the adequate number of toilets based on the workforce. 22 Occupational Safety and Health Health Services and First Aid No medical checks provided to workers exposed to work-related hazards. 22 Jul-17 Occupational Safety and Health Health Services and First Aid No annual medical checks provided to workers. Arrange, at least, two medical checks for workers exposed to work-related hazards. Arrange an annual medical check for every worker. Jul-17 Occupational Safety and Health Health Services and First Aid Insufficient number of medical staff. Hire sufficient medical staff based on the workforce. 22 22 105 Jul-17 Occupational Safety and Health Health Services and First Aid Les than 10 per cent of the workforce trained in first aid. Train 10% of the workforce in first aid. Jul-17 Occupational Safety and Health Emergency Preparedness No fire detection system in the back warehouse. Jul-17 Occupational Safety and Health Emergency Preparedness The power outlet in the spot cleaning was not safeguarded. Ensure the workplace has adequate firefighting equipment. Install fire detection system in the back warehouse. Safeguard any source of ignition. Cover the power outlets. Jul-17 Working Time Overtime No valid authorization from the Department of Labour prior working overtime. 22 The factory hired a new compliance officer to reinforce OSH compliance. 22 The factory hired a new compliance officer to reinforce OSH compliance. 11 Ensure to obtain a valid It is longer required by law to authorization from the Department obtain a valid authorization of Labour before working overtime. from the Department of Labour before working overtime. However, the factory is still requesting such 22 106 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Date of last two Better Work assessments: HANSAE HAITI S.A Port-au-Prince 2013 Jan-17 Apr-18 Apr-17 Advisory and Training Services 26-Feb-19 Factory visit to discuss grievance Mechanism and effective functioning of bipartite committees. 28-Jan-19 Training Respectful Workplace Program with Electra Sewing. 13-Dec-18 Training in Risk Management & Control 10-Dec-18 Factory visit to conduct Sexual Harassment Training 27-Nov-18 Training in Sexual Harassment in the events of Share Hope 12-Oct-18 Training in Sexual Harassment Awareness and Prevention Awareness for Supervisors & Workers ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT DETAILS OF NON COMPLIANCE IMPROVEMENT PRIORITIES REMEDIATION EFFORTS MONTHS Assessment April 2018 Apr-18 Compensation Paid Leave The sick leave payment is based on minimum wage. Change payment system based on the average daily earnings Payment system changed accordingly based on the average daily earnings. 12 Apr-18 Contract and Human Resources Termination Management provides notice payment based on minimum wage. Change payment system based on the average daily earnings. The payment system changed accordingly based on the average daily earnings. 12 Apr-18 Occupational Safety and Health Chemicals and Hazardous Substances No MSDS were available in the mechanic room of building 21 for Acid sulfuric also in the spot cleaning of building 50 for FH 2000. Provide training to workers on chemical handling. Post required MSDS as required in local language. The MSDS's was posted on the same day. Training on chemical handling has been provided to all maintenance and mechanics workers . 12 Apr-18 Occupational Safety and Health Worker Protection 1 uncovered electrical boxes near the fabric warehouse. Cover the electrical panel with nonflammable material. Provide training to workers on electrical safety and fire safety. The material used to cover the panel is adequate. 12 Apr-18 Occupational Safety and Health Health Services and First Aid Expired products in first aid box #2 and #4 such as Betadine and triple antibiotic ointment. Training should be provided to the nurses on medicine storage maintenance & management. Training was provied to the nurses and doctor regarding medicine storage management. 12 107 Apr-18 Occupational Safety and Health Emergency Preparedness One fire extinguisher near the training area, also another one near the sewing section of building 50 were undercharged. Discuss issue with third party provider to remediate root cause. Conduct monthly inspections of fire extinguishers. Factory replaced BC type fire extinguishers to ABC types. The former had manufacturing malfunction which caused them to lose charge. Assessment Janurary 2017 Jan-17 Compensation Social Security and Other Benefits The factory has not yet sent their contribution to OFATMA for maternity and health insurance Register with OFATMA for maternity and health insurance and ensure OFATMA payment are made on time Factory is registered with OFATMA for maternity and health insurance and payments are made on time. Jan-17 Compensation Social Security and Other Benefits The factory does not collect and forward worker's contribution to OFATMA for maternity and health insurance Collect and forward workers contribution to OFATMA for maternity and health insurance Factory collects and forward worker's contributions to OFATMA for maternity and health insurance. Jan-17 Compensation Worker Protection Workers not using training received on the use of PPE in some areas. Assign person to monitor the usage of the PPE on a daily and consistent basis. Training was done for workers on the use of PPE and random factory tours remind workers on the use consistently. Jan-17 Occupational Safety and Health Health Services and First Aid The factory has one onsite nurse and there are no weekly doctor's visits. Hire the additional required level of medical staff. The factory hired an additional nurse and a Doctor who works 3 times a week. Jan-17 Occupational Safety and Health Health Services and First Aid 10 percent of the workforce are not trained in first aid Ensure that at least 10 percent of workers are trained in first aid. First-Aid training was done for 10% of the workforce by the compliance officers and the nurse. Jan-17 Working Time Overtime No authorization has yet been obtained from the Ministry of Labor to perform overtime Request authorization to work overtime from MAST. The factory received an authorization to perform overtime from MAST for the period of April 3 to June 30. Jan-17 Occupational Safety and Health Emergency Preparedness Less than 10 percent of the workforce are trained in fire fighting equipment. Update the training plan to ensure that at least 10 percent of the workforce receive training in fire fighting equipment. Compliance officers trained 10.5% workers on firefighting equipment and the use of fire extinguishers. 12 108 Jan-17 Occupational Safety and Health Emergency Preparedness Some fire extinguishers were with inadequate pressure. Conduct internal inspection once a month to regulate pressurization. External Inspection is done for all fire extinguisher by outside contractor and monthly internal inspection by the compliance officers. 109 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Date of last two Better Work assessments: Horizon Manufacturing S.A. Port-au-Prince 614 Aug-10 Apr-17 Apr-18 Advisory and Training Services 7-Mar-19 Factory visit to discuss on factory's current situation and improvement. Revision of the improvement plan. Review of documentation. Factory tour to validate the remediation. Meeting with the union on the social dialogue situation with the management. 13-Dec-18 7-Dec-18 27-Nov-18 Risk Management & Control Workshop on the challenges faced by women in the workplace Sexual Harassment in the events of Share Hope ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT DETAILS OF NON COMPLIANCE IMPROVEMENT PRIORITIES REMEDIATION EFFORTS MONTHS Assessment April 2018 Apr-18 Compensation Paid Leave Payments for non-working holidays are based on average hourly production wage which does not include overtime hours. Include overtime wages in the calculation of paid leave. 17 Apr-18 Compensation Paid Leave Sick leave payments are based on average hourly production wage instead of average daily earnings. Include the overtime wages in the calculation of sick leave. 5 Apr-18 Compensation Paid Leave Maternity leave payments are based on average hourly production wage instead of average daily earnings. Include overtime wages in the calculation of maternity leave. 5 Apr-18 Compensation Social Security and Other Benefits Late ONA payment. Forward employer's contribution to ONA within the first 10 days of each month for the previous month. 17 110 Apr-18 Compensation Social Security and Other Benefits Late ONA payment. Collect and forward workers' contribution to ONA within the first 10 days of each month for the previous month. 17 Apr-18 Compensation Social Security and Other Benefits OFATMA payment for maternity and Health insurance is late by several months. Forward employer's contribution to OFATMA on monthly basis. 17 Apr-18 Compensation Social Security and Other Benefits OFATMA payment for maternity and Health insurance is late by several months. Collect and forward workers 'contribution to OFATMA on a monthly basis. 17 Apr-18 Occupational Safety and Health OSH Management Systems The OSH policy has not been developed in consultation with workers and their representatives. Review the OSH policy in consultation with workers' representatives and also include legal requirements pertaining to OSH. 5 Apr-18 Occupational Safety and Health Chemicals and Hazardous Substances Keep the inventory of chemical updated. 17 Apr-18 Occupational Safety and Health Chemicals and Hazardous Substances No updated inventory is available for chemicals and hazardous substances used in the workplace. Unidentified containers. 17 Apr-18 Occupational Safety and Health Chemicals and Hazardous Substances Chemicals were not stored properly. Assign accountability to maintenance team and train workers in chemical handling procedures. Keep and store chemical substances in an adequate area. Apr-18 Occupational Safety and Health Chemicals and Hazardous Substances No MSDSs for paints, diesel and electrolyte were available in the chemical room. Ensure that MSDS are available for all the chemicals used in the factory. Train workers in chemical handling procedures. 17 Apr-18 Occupational Safety and Health Chemicals and Hazardous Substances No documented evidence of actions taken by management to control and oversee workers' exposure to chemicals and hazardous substances were unavailable. Train workers that are using chemicals and hazardous substances. 5 Apr-18 Occupational Safety and Health Chemicals and Hazardous Substances No eye wash station in the laundry room where chemicals and hazardous substances are used. Install an eye wash station in the laundry room. 29 5 111 Apr-18 Occupational Safety and Health Worker Protection The factory did not provide earplugs for workers in the generator room. Provide earplugs for workers in the generator room. 17 Apr-18 Occupational Safety and Health Worker Protection Standing workers in the packing area and quality section were not provided with foot rests or shock absorbing mats. Provide foot rests or shock absorbing mats to standing workers in the packing area and quality section. 17 Apr-18 Occupational Safety and Health Worker Protection Electrical installations not properly maintained. Ensure the electrical system is properly maintained. Ensure that sources of ignition are properly safeguarded. 17 Apr-18 Occupational Safety and Health Worker Protection One electrical panel missing safety warning signs in the Laundry room. Post safety warning sign is posted in the electrical panel in the Laundry room of building 31. 17 Apr-18 Occupational Safety and Health Working Environment Temperature levels exceeded 30 C in all sections. Ensure that temperature is below 30 C. 17 Apr-18 Occupational Safety and Health Working Environment The level of lighting in the workplace were inadequate in the sewing and quality sections. Ensure that the workplace is adequately lit. 17 Apr-18 Occupational Safety and Health Welfare Facilities Soap was not available in building 32 and 31. Ensure that soap is available in the toilets. Apr-18 Occupational Safety and Health Welfare Facilities The eating area can only accommodate 50 percent of the workers. Ensure that the eating area cam accommodate all the workers Apr-18 Occupational Safety and Health Health Services and First Aid Factory does not provide health checks to workers exposed to workrelated hazards. Ensure that workers exposed to work-related hazard receive an health check twice a year. The maintenance team receive instruction to regularly check on the availability of the soaps and papers. 5 5 The factory scheduled more than two Health checks for two workers who are exposed to workrelated hazards. The two workers completed the second medical check ups in August 2018 17 112 Apr-18 Occupational Safety and Health Health Services and First Aid Insufficient number of onsite medical staff. Ensure that the medical staff is compliant regarding the Haitian Labour Law requirements.. Since the company has reduced its workforce and operate with less 700 workers. The number of medical staff available in the factory is compliant with the labour Code. 17 Apr-18 Occupational Safety and Health Health Services and First Aid One first aid box was not readily accessible in the pressing section. Ensure that all first aid box are accessible during the working time. The key keepers are two people working in the area of the first aid. Their pictures are posted above the box, so the workers can identify who they are. 5 Apr-18 Occupational Safety and Health Health Services and First Aid Less than the 10 percent of the workforce are trained in first aid. Ensure that 10 percent of the workforce is trained in first aid. Apr-18 Occupational Safety and Health Emergency Preparedness Access to 1 fire extinguisher was obstructed and fire extinguisher was missing in the packing area of building 52. Ensure the workplace has an adequate firefighting system. Perform regular OSH assessment. Apr-18 Occupational Safety and Health Emergency Preparedness Less than the 10 percent of the workforce ere trained in firefighting. Train 10 percent of the workforce in firefighting. Apr-18 Occupational Safety and Health Emergency Preparedness Evacuation map in building 32 is inaccurate. Update the evacuation plan in building 32 accordingly. Apr-18 Working Time Regular Hours The employer has not posted the factory's working hours. Post factory's working hours. 17 Global S.S is responsible to check the fire extinguisher on a regular basis. Internally, the compliance team is responsible to perform on a monthly basis; 5 The evacuation has been updated to reflect the floor layout. Compensation Overtime Wages Overtime hours worked at night were not compensated at 100 percent above the normal wage. Pay night shift accordingly. 5 17 Assessment April 2018 Apr-17 17 Contracted with a security company for the shift at night since the same month of the audit of last year. 113 Apr-17 Compensation Paid Leave Payments for non-working holidays are based on the minimum wage instead of average earnings. Pay holidays payment accordingly with the Labour Code. The factory is paying the non-working holidays on the average earnings. Apr-17 Compensation Paid Leave Payments for weekly rest days are based on the minimum wage instead of average earnings. Pay the weekly rest day accordingly with the Labour Code. The factory paid the weekly rest day based on average since June 2017. Apr-17 Compensation Social Security and Other Benefits Late ONA payment Comply with the law regarding the ONA deductions. The factory calculated the ONA deduction on basis salary as stipulated by the law. Apr-17 Compensation Social Security and Other Benefits Late ONA payment Comply with the legal requirements regarding ONA's deductions. The factory calculated the contribution to ONA on basis salary as required by the law. Apr-17 Compensation Social Security and Other Benefits Factory is not registered with OFATMA for maternity and health insurance services. Register the workers of Building 32 in OFATMA for maternity and health insurance services. All workers of Building 32 are registered in OFATMA for maternity and health insurance. The factory started to pay the monthly deductions to OFATMA. Apr-17 Compensation Social Security and Other Benefits Factory is not registered with OFATMA for maternity and health insurance services. Pay OFATMA's insurance for maternity and health for workers of Building 32. Ensure that OFATMA's deduction are accurate. Building 32 is registered for OFATMA' s maternity and health insurance. The calculation is based on the basis salary. Apr-17 Contract and Human Resources Termination No evidence of notifying MAST prior to the temporary suspension made in 2017. Send a letter to Ministry of Labour prior to the temporary suspension. The factory came out with new strategies that will help to ameliorate the communication between the Human Resource department and the Production department regarding the increase and reductions of the workforce. Apr-17 Occupational Safety and Health OSH Management Systems Records for work-related accidents were unavailable. Send monthly work-related accidents and diseases records to OFATMA. The Factory is sending the report on a monthly basis. 114 Apr-17 Occupational Safety and Health Chemicals and Hazardous Substances No updated inventory of chemicals and hazardous substances was available. Keep an inventory of chemicals and hazardous substances used in the workplace. The factory keeps an inventory of chemicals. Apr-17 Occupational Safety and Health Chemicals and Hazardous Substances During the factory tour, EAs observed 2 unlabelled chemical containers in the chemical Room of Building 32. Management explained that it was containers of sewing machine engine oil. Label all chemical containers used in the workplace. The factory labelled all chemical containers of the chemical room. Apr-17 Occupational Safety and Health Chemicals and Hazardous Substances No MSDS were found for thinner and blow out in the spot Cleaning areas, nor in the chemical storage area of Buildings 32. Post MSDS for chemicals used in the workplace in the area where they are used or stored. During the assessment, the factory took immediate corrective action and post the corresponding MSDS' in spot cleaning and chemical storage area. Apr-17 Occupational Safety and Health Chemicals and Hazardous Substances Documented evidence of chemical safety trainings conducted for workers were unavailable. Document and record safety training. The factory started to record their training. Last safety trainings provided are recorded. Apr-17 Occupational Safety and Health Chemicals and Hazardous Substances No eye washing facilities were available in the spot cleaning area of Building 32 and chemical room of Building 31. Provide cleaning facility where needed. The factory installed one eye-wash station in building 32. They have installed one near the chemical area Apr-17 Occupational Safety and Health Worker Protection Inappropriate masks were provided to workers using chemicals in the spot cleaning area of Building 32. Provide appropriate personal protective equipment to workers who are using chemicals. The factory bought appropriate masks for workers in cleaning area. The workers were trained on how to use the equipment appropriately. Apr-17 Occupational Safety and Health Worker Protection Shock absorbing mats were not provided to several standing workers. Provide shock absorbing mats or foot rest to standing workers in the Packing and the Inspection sections of Building 32. Factory provided shock absorbing mats to all standing workers. 115 Apr-17 Occupational Safety and Health Worker Protection Sewing machines were missing necessary guards. Install all necessary guards on the machines. The pulley guards are installed on all machines in both building. Eye guard are installed at 95%. The issue with the missing finger guards is still pending. Apr-17 Occupational Safety and Health Worker Protection Several electrical wires were dusty or uncovered and electrical box was obstructed. Ensure to safeguard all potential source of ignition. Maintain properly the electrical system. The factory unblocked all electrical boxes. Apr-17 Occupational Safety and Health Working Environment Temperature level exceeded 30 C in all sections. Ensure that the temperature level is under 30 C. Apr-17 Occupational Safety and Health Working Environment Light levels were inadequate in Sewing, packing, inspection and cutting section. Ensure that light levels are appropriate. Apr-17 Occupational Safety and Health Working Environment The Compressor Room in Building 32 is not clean and tidy. Ensure that the Compressor Room is clean and tidy. The factory designed a person to be in charge of the compressor room. He is also responsible to clean the area regularly. Apr-17 Occupational Safety and Health Welfare Facilities Insufficient number of toilets. Ensure to have the required number of toilets. The required number of toilets is functioning and available to workers. Apr-17 Occupational Safety and Health Health Services and First Aid No medical checks arranged for newly hired workers within the first three months of employment. Arrange a medical check for newly hired workers within the first three months. The factory is scheduling with the onsite doctor check ups as a way to perform a medical check for the newly hired workers within their first three months. Apr-17 Occupational Safety and Health Health Services and First Aid No periodic medical checks were arranged for workers who have been exposed to work-related hazards. Arrange, at least, two medical checks for workers who have been exposed to work-related hazards. The factory arranged with the onsite doctor, a schedule to provide periodic medical checks for workers who have been exposed to work-related hazards. 116 Apr-17 Occupational Safety and Health Health Services and First Aid Annual medical checks were not arranged for all the workers . Arrange Health checks for workers, at least once a year. The factory has planned with OFATMA to perform the remained checks before the end of the year. Apr-17 Occupational Safety and Health Health Services and First Aid Insufficient number of onsite medical staff. Have a permanent onsite medical service, with at least 3 nurses and 3 doctor's visits per week. The factory signed a new contract with the doctor. The doctor will provide a permanent onsite service of 6 consecutive days per week. Three days for each building. Apr-17 Occupational Safety and Health Health Services and First Aid Less than 10 per cent of the workforce trained in first-aid. Train a sufficient number of workers. The factory trained 40 workers in first-aid this year. With the previous workers trained in the past years, the factory is compliant for that concern. Apr-17 Occupational Safety and Health Emergency Preparedness Three fire extinguishers were obstructed and fire extinguisher was overcharged. Ensure that the fire extinguishers remain unobstructed. Regularly check the firefighting equipment. Internal check performed everyday. Apr-17 Occupational Safety and Health Emergency Preparedness One fire drill performed in last twelve months. Ensure to perform 2 fire drill every 12 months. The factory made two drills in 2017: in February and in august 2017. Apr-17 Working Time Regular Hours Pregnant women were not aware of their right to take two additional breaks of half hour each. Make a policy to communicate on the fact that pregnant women are entitled to have 2 additional break time of 30 minutes more the normal lunch time. The factory had an awareness meeting with all the pregnant women. Notices are posted throughout the floor. 117 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Date of last two Better Work assessments: LIFE S.A Port-au-Prince 57 Sep-09 Oct-17 Dec-18 Advisory and Training 23-Mar-19 4-Dec-18 Factory visit to discuss with management on improvement plan and general update. Review of documentation. Factory tour to validate the progress. Training of Trainer supervisory Skills (ToT SST) ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT DETAILS OF NON COMPLIANCE IMPROVEMENT PRIORITIES REMEDIATION EFFORTS MONTHS Assessment December 2018 Dec-18 Compensation Paid Leave Factory pays for 6 weeks while it is not registered in OFATMA health and maternity insurance. The factory is not affiliated with OFATMA for health and maternity insurance. Dec-18 Compensation Social Security and Other Benefits Dec-18 Compensation Social Security and Other Benefits The factory is not affiliated with OFATMA for health and maternity insurance. Dec-18 Contract and Human Resources Employment Contracts Several copies of workers contracts are not dated and signed. Dec-18 Occupational Safety and Health OSH Management Systems The OSH committee is not functioning. Comply with the law and register in OFATMA maternity and Health insurance. Comply with the law and register with OFATMA for maternity and Health insurance. Collect and forward the related deductions on a monthly basis Comply with the law and register with OFATMA for maternity and Health insurance. Collect and forward the related deductions on a monthly basis Ensure that all the workers contracts are signed and dated. Have a reliable process to ensure that all the workers file are properly documented. Assign a dedicated staff to follow up on the regularity of workers documents. Ensure to have a functioning health and safety committee. Dec-18 Occupational Safety and Health Chemicals and Hazardous Substances Calculation of sick leave is not based on the average daily earnings during the previous 3 months of work. Ensure that the inventory has all the necessary information (location, quantities, etc..) and is kept updated. Dec-18 Occupational Safety and Health Worker Protection The generator was not properly grounded. Ensure that electrical panels located in the generator and compressor area are properly safeguarded and sealed. Ensure that the generator is grounded. 6 The factory sent the registration form to OFATMA for maternity and health insurance in order to complete the process. 30 The factory sent the registration form to OFATMA for maternity and health insurance in order to complete the process. 30 At end of 2018, management terminated all workers to submit new temporary contracts. All new contracts are signed both by management representative and concerned worker. 6 6 The management updated the chemical inventory during the assessment visit. 30 6 118 Dec-18 Occupational Safety and Health Working Environment Temperature level exceeded 30C. Ensure that the temperature level is acceptable. 30 Dec-18 Occupational Safety and Health Working Environment Light level was inadequate in the inspection section. 6 Dec-18 Occupational Safety and Health Emergency Preparedness Inaccuracy of the evacuation plan Ensure that the light levels are acceptable in the quality section Update the evacuation plan to include a clear evacuation path. 18 Assessment July 2018 Jul-17 Compensation Social Security and Other Benefits Inaccuracy of ONA's deductions. Calculate ONA deductions based on worker's base salary. All payments are included in the calculation of ONA except overtime. Jul-17 Compensation Social Security and Other Benefits Inaccuracy of ONA's deductions. Make the ONA payment accordingly. Ensure to pay ONA's deduction on time. All payments are included in the calculation of ONA except overtime. Jul-17 Compensation Social Security and Other Benefits The factory is not affiliated with OFATMA's maternity and health insurance. Register with OFATMA for maternity and health insurance Jul-17 Compensation Social Security and Other Benefits The factory is not affiliated with OFATMA's maternity and health insurance. Register with OFATMA for maternity and health insurance Jul-17 Occupational Safety and Health OSH Management Systems The OSH policy is not signed by top management and was not developed in consultation with workers representatives. Review the OSH policy. Obtain top management signature. The OSH policy is signed by top management. Jul-17 Occupational Safety and Health Chemicals and Hazardous Substances The factory does not maintain an updated inventory of the chemicals and hazardous substances used. Keep an updated inventory of chemicals and hazardous substances used in the workplace. The factory keeps an inventory of chemical substances used in the workplace Jul-17 Occupational Safety and Health Worker Protection Some standing workers were not provided with foot rests or shock absorbing mats. Provide foot rests or shock absorbing mats to standing workers. All factory equipped all inspection tables with footrests. All standing workers has been trained about their usage Jul-17 Occupational Safety and Health Working Environment Temperature level exceeded 30C. Ensure that the temperature level, inside the workplace is under 30C Jul-17 Occupational Safety and Health Health Services and First Aid No health checks provided to workers within the first three months of hiring. Ensure that workers receive proper health checks within the first three months of hiring The factory hired a doctor who comes 3 times a week and 1 Saturday a month to provide health checks to workers. 119 Jul-17 Occupational Safety and Health Health Services and First Aid The factory does not provide workers with proper annual health checks Ensure that all workers received an annual check. Properly Document all the evidences of annual checks provided. The factory hired a doctor who comes 3 times a week and 1 Saturday a month to provide health checks to workers. Jul-17 Occupational Safety and Health Health Services and First Aid Insufficient number of medical staff. Ensure to have a permanent onsite medical service with at least, 1 nurse and 2 doctor's visits per week. The factory has a permanent onsite medical staff with 1 nurse and 3 doctor's visits per week. Also the doctor comes 1 Saturday every month. Jul-17 Occupational Safety and Health Emergency Preparedness Inaccuracy of the evacuation plan Update the evacuation plan in the fabric warehouse 120 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: MAS AKANSYEL S.A Caracol 926 Jul-17 Jan-19 Nov-17 Advisory and Training Services 27-Mar-19 Bipartite meeting to discuss female toilets, sick leave request and payroll. 27-Feb-19 Bipartite meeting to discuss incentives 23-Jan-19 Bipartite committee to discuss temperature, noise levels from cooling system and incentives for cutting section. 27-Nov-18 Bipartite committee meeting to discuss income tax issues, incentives and uniforms 12-Nov-18 Bipartite meeting to discuss year end vacation schedule and bonuses. 9-Nov-18 Factory visit to discuss partnership with factory & national Partners 9-Nov-18 Building Bridges Workshop 8-Nov-18 Factory visit for Documentation Review to check adequate payments on Terminations, Contracts- Compliance Officer 8-Nov-18 Training in Sexual Harassment Awareness and Prevention Middle Management 25-Oct-18 Training in ToT Sexual Harassment 20-Oct-18 Bipartite Meeting to discuss issues at ATM during pay day, production managers not approving sick leave, worker not getting paid for sick leave. 18-Oct-18 Training in Supervisory Skills (SST) 16-Oct-18 Training of Trainer supervisory Skills (ToT SST) ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT DETAILS OF NON COMPLIANCE IMPROVEMENT PRIORITIES REMEDIATION EFFORTS MONTHS Assessment Januray 2018 Jan-19 Compensation Overtime Wages The factory needs an authorization from MAST to work 9 regular hours from Monday to Friday. Obtain authorization from MAST to work 9 regular working hours a day. 2 Jan-19 Compensation Social Security and Other Benefits The factory has not contributed yet to OFATMA for work-related accident insurance for the fiscal year 2018/2019. Ensure contribution to OFATMA for work-related accident insurance for the fiscal year is current as required. 2 Jan-19 Contract and Human Resources Termination Calculation for termination notice payments is not based on the average salary for the last 3 months as required by law but on the minimum wage. Ensure notice payment to terminated workers are based on the average salary for the last 3 months as required by law not on the minimum wage 2 121 Jan-19 Occupational Safety and Health Chemicals and Hazardous Substances The factory does not maintain an inventory for all chemicals and hazardous substances used in the workplace. Assign responsible persons for updating inventories of all hazardous substances in the various locations where they are stored or used and checking if the inventory is updated. 2 Jan-19 Occupational Safety and Health Chemicals and Hazardous Substances During the factory tour, assessors found unidentified containers of thinner, Alcohol, liquid soap all around the workplace. Properly label chemicals and hazardous substances including name in local language and hazard pictogram. Assign responsibilities for chemical handling. 2 Jan-19 Occupational Safety and Health Chemicals and Hazardous Substances No MSDS were posted in some areas where chemicals are stored or used. Identify dedicated person in OSH committee that ensures MSDS are available in local language for all chemicals. 2 Jan-19 Occupational Safety and Health Chemicals and Hazardous Substances Assessors observed that no washing facility was available near the spot cleaning where chemical and hazardous substance are used. Provide washing facility to the spot cleaning areas and where all chemical and hazardous substance are used. 2 Jan-19 Occupational Safety and Health Worker Protection Workers in the spot cleaning section were provided with dust mask which is inappropriate for the risks of chemical inhalation. Distribute appropriate mask to workers of the spot cleaning section to protect against the risks of chemical inhalation. 2 Jan-19 Occupational Safety and Health Worker Protection The factory did not provide any evidence of training records with date and number of participants on the proper use of machines and personal protective equipment. Conduct and keep evidence of training records with date and number of participants on the proper use of machines and personal protective equipment. 2 Jan-19 Occupational Safety and Health Worker Protection Several standing workers in packing area and in the training area were observed without shock absorbing mats. Ensure availability and distribution of shock absorbing mats to standing workers where appropriate. Ensure all chairs used on the floors are ergonomically sound as appropriate. 2 122 Jan-19 Occupational Safety and Health Working Environment Workplace temperature in the quality and packing sections exceeds 31 C . Use electrical exhaust fans or cooling system. Monitor workplace temperature on a regular basis. 2 Jan-19 Occupational Safety and Health Working Environment Noise levels exceed 90DB in the quality section. Provide ear muffs to workers in that section if noise cannot be controlled below 90DB 2. Perform random noise level measurements. 2 Jan-19 Occupational Safety and Health Health Services and First Aid Management did not arrange 2 yearly medical checks for workers exposed to work related hazards. Ensure that the factory is current with payments of health cards. Arrange with OFATMA to have 2 yearly medical checks for workers exposed to work related hazards 2 Jan-19 Occupational Safety and Health Health Services and First Aid Management did not arrange one annual medical check for all the workers. Ensure that the factory is current with payments of health cards. Arrange with OFATMA to have annual medical check for all the workers. 2 Jan-19 Occupational Safety and Health Health Services and First Aid One expired product named Neosporin was found in two first aid boxes. Assign dedicated person from OSH committee to perform weekly checks of first aid boxes with factory nurse. Maintain inventory log with expiration dates of all products as appropriate 2 Jan-19 Occupational Safety and Health Health Services and First Aid Workers trained in first-aid were less than the recommended 10 percent of the workforce. Conduct first aid training for recommended 10 percent of the workforce. Maintain dates, names and number of participants. 2 Jan-19 Occupational Safety and Health Emergency Preparedness One alarm in the stock trim warehouse that was obstructed and not visible to everyone in the workplace. Assign responsible person from OSH committee for fire detection system monitoring. Ensure that fire detection systems are visible and not obstructed 2 123 Jan-19 Occupational Safety and Health Emergency Preparedness Fire extinguishers with low pressure in the spare parts room and unidentified and not properly mounted in stock trim warehouse. Assign responsible person from OSH committee for fire extinguisher monitoring. Submit weekly reports to compliance manager 2 Jan-19 Occupational Safety and Health Emergency Preparedness Evacuation maps are not posted on the floor. In addition the evacuation map does not show the escape routes, the exits and fire extinguishers. Ensure updated evacuation maps are posted on the floor. Ensure that the updated maps display escape routes, exits and fire extinguishers. 2 Jan-19 Occupational Safety and Health Emergency Preparedness Escape routes were blocked by sewing machines in the sewing lines Improve induction training on emergency preparedness. Inform the supervisor about their responsibilities to ensure escape routes are not obstructed. Assign someone from OSH committee to perform random OSH tours. 2 Jan-19 Working Time Emergency Preparedness Flammable material such as piles of cardboard boxes stacked on top of each other next to an electric panel. Ensure that all flammable items are properly stored. 2 Jan-19 Contract and Human Resources Regular Hours The factory needs an authorization from MAST to work 9 regular hours per day from Monday to Friday. This authorization was not presented at the time of assessment visit. Obtain authorization from MAST to work 9 regular hours. 2 Assessment November 2018 Nov-17 Occupational Safety and Health Chemicals and Hazardous Substances There was no eye wash station installed where chemicals are stored at the time of the assessment. Ensure that properly functioning eye wash stations are accessible where chemicals and hazardous substances are stored. Nov-17 Occupational Safety and Health Working Environment Workplace temperature exceed 31 C in all sections. Use electrical exhaust fans or cooling system. Monitor workplace temperature on a regular basis. 124 Nov-17 Occupational Safety and Health OSH Management Systems No evidence of a general occupational safety and health assessment were available. Maintain accessible internal OSH assessment reports. Factory document and centralize all records of internal assessments to render more accessible for external assessors. Nov-17 Occupational Safety and Health OSH Management Systems The factory OSH policies were not developed through consultation with workers and their representatives. Management to secure a date with bipartite committee to discuss/revise OSH policy based on mutual consultations. OSH policy has been discussed in bipartite committee for input from worker representatives. Nov-17 Occupational Safety and Health Chemicals and Hazardous Substances Factory does not maintain an inventory of chemicals and hazardous substances used in the workplace. Set up inventory management system for the appropriate storage, tracking and labelling of chemicals and hazardous substances used in the workplace. Nov-17 Occupational Safety and Health Chemicals and Hazardous Substances Assessors observed unidentified bottles of oil and thinner in the mechanic shop. Set up inventory management system for the appropriate storage, tracking and labelling of chemicals and hazardous substances used in the workplace. Nov-17 Occupational Safety and Health Chemicals and Hazardous Substances Chemicals and hazardous substances were not stored properly. Set up inventory management system for the appropriate storage, tracking and labelling of chemicals and hazardous substances that are in use. Nov-17 Occupational Safety and Health Chemicals and Hazardous Substances No MSDS were posted in the area where chemicals are stored near the mechanic shop. Set up inventory management system for the appropriate storage, tracking and labelling of chemicals and hazardous substances used in the workplace. Nov-17 Occupational Safety and Health Worker Protection All electrical boxes lacked a warning sign. Prepare and post safety warnings for all electrical boxes. Safety warnings were posted 125 Nov-17 Contract and Human Resources Employment Contracts The factory has internal work rules that are not yet approved by the Ministry of Labour. Obtain approval from the labour ministry for internal rules and post on factory floor. Nov-17 Contract and Human Resources Termination Termination records reveals that at the time of the termination of employment, the payment of the workers does not include the annual salary supplement or bonus. Properly calculate and pay salary supplement or bonus as part of severance payments. Nov-17 Occupational Safety and Health Health Services and First Aid The first aid boxes were stored in the office of human resources. . Ensure that all first aid boxes are accessible to workers on the factory floor. Internal work rules were approved by the labour ministry. All first aid boxes are accessible to workers on the factory floor. 126 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Date of last two Better Work assessments: Modas BU IL S.A. Port-au-Prince 1566 Aug-14 Apr-18 Apr-17 Advisory and Training Services 12-Apr-19 5-Apr-19 7-Feb-19 7-Dec-18 30-Nov-18 30-Nov-18 27-Nov-18 Meeting with management to discuss union termination issue Bipartite committee meeting to reflect on the progress accomplished during the past cycle. Factory tour. Factory tour to verify remediation of OSH issues Workshop on challenges of women in the workplace Training on Sexual Harassment Awareness and Prevention Middle Management & Supervisors Training on Sexual Harassment Awareness and Prevention Workers Training on Sexual Harassment in the events of Share Hope ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT Apr-18 Compensation Social Security and Other Benefits Apr-18 Compensation Apr-18 Apr-18 DETAILS OF NON COMPLIANCE IMPROVEMENT PRIORITIES REMEDIATION EFFORTS MONTHS The payment of the employer's contribution to ONA was late. Ensure that ONA is paid every months within the first 10 days. ONA payment were completed in a timely manner. 12 Social Security and Other Benefits The employer collects workers' contribution to ONA on a regular basis. However, the payment of the workers' contribution to ONA is not submitted on time. Ensure that ONA is paid every months within the first 10 days. ONA payment were completed in a timely manner. 13 Contract and Human Resources Employment Contracts Workers' contracts did not specify the hours of work as required by law. Revise contracts to ensure that working hours are included. The contracts were revised to specify the hours of work as required by law. 14 Occupational Safety and Health OSH Management Systems The factory has a written OSH policy that has not been developed in consultation with workers and their representatives. Review the OSH policy to include reference to compliance with labor law requirements pertaining to OSH. Present the OSH policy to workers' representatives to gather their feedback and update the OSH policy as required before signature. Assessment April 2018 15 127 Apr-18 Occupational Safety and Health Worker Protection Several sewing machines missing safety guards. Install the missing machine guards. Ensure regular verification and maintenance. The factory installed the missing machine guards. The mechanics team is in charge of ensure regular verification and maintenance. The new compliance officer does regular auditinstalled an The factory 16 Apr-18 Occupational Safety and Health Emergency Preparedness No alarm system was installed in building 53 B. Install alarm system were installed in building 53 B Apr-18 Occupational Safety and Health Worker Protection Batteries were placed on a wooden box instead of steel frame in the generator room. A damaged drill power cord was connected directly inside an electrical panel in the same generator room. Apr-18 Occupational Safety and Health Welfare Facilities The eating area can only accommodate 20 percent of the workers. Add more seats in the eating area. Consider having 2 shifts for lunch break. Apr-18 Occupational Safety and Health Health Services and First Aid The factory does not provide workers health checks within the first three months of hiring. Provide workers health checks within the first three months of hiring. Keep adequate records. The recruitment procedures were reviewed to request health certificate as part of the hiring process. 20 Apr-18 Occupational Safety and Health Health Services and First Aid The factory does not provide health checks to workers exposed to work-related hazards. Provide health checks to workers exposed to workrelated hazards. Keep adequate records. 0 21 Apr-18 Occupational Safety and Health Chemicals and Hazardous Substances The chemicals inventory was incomplete. Review procurement procedures to ensure that chemicals management is centralized. Ensure that one single inventory of all chemicals used in the workplace is maintained and updated. Communicate this new policy to all relevant staff. The factory has one updated single inventory of all chemicals used in the workplace is maintained and updated. The factory has a chemicals management procedure. 22 17 alarm system were installed in building 53 B. OSH training was offered to Electrical Technicians in order to avoid the risk in Factory. HR Manager and Compliance manager monitor the workplace on a regular basis. 0 18 19 128 Apr-18 Occupational Safety and Health Chemicals and Hazardous Substances Chemicals and hazardous substances such as Thinner used in the mechanic workshop and the fusing area were not properly labelled. Review procurement procedures to ensure that chemicals management is centralized. Ensure that all chemicals used in the workplace are properly labelled. Communicate this new policy to all relevant staff. All chemicals found in the workplace are labelled. The factory has a chemicals management procedure. 23 Apr-18 Occupational Safety and Health Chemicals and Hazardous Substances MSDS were missing for some chemicals and hazardous substances. Review procurement procedures to ensure that chemicals management is centralized. Ensure that MSDS are posted for all chemicals used in the workplace. Communicate this new policy to all relevant staff. MSDS are posted for all chemicals used in the workplace. The factory has a chemicals management procedure. 24 Apr-18 Occupational Safety and Health Chemicals and Hazardous Substances Workers were found using chemicals without PPE in the fusing area. Provide PPE in the fusing section where workers were found using chemicals. Consider alternatives to reduce workers' exposure to chemicals in this area. PPE were provided in the fusing section where workers were found using chemicals. 25 Apr-18 Occupational Safety and Health Chemicals and Hazardous Substances There was no eye wash station in the spot cleaning near the entrance of floor 53 B and the Fusing area. Install eye wash station in the spot cleaning near the entrance of floor 53 B and the Fusing. Eye wash station was installed in the spot cleaning near the entrance of floor 53 B and the Fusing. 26 Apr-18 Occupational Safety and Health Worker Protection Management did not provide gloves and masks for workers in the ironwork workshop shop area using Thinner. Provide gloves and masks for workers in the ironwork workshop shop area using Thinner. Earmuffs for workers in the generator room were provided .Gloves and masks were provided for workers in the ironwork workshop shop area using Thinner. 27 Apr-18 Occupational Safety and Health Health Services and First Aid Insufficient medical staff. Hire 5 additional nurses as required by law. 0 28 Apr-18 Occupational Safety and Health Health Services and First Aid Expired product were found in the first aid boxes. Replace the expired products from the first aid boxes. Conduct regular OSH assessment to ensure the availability of proper products. 29 129 Apr-18 Occupational Safety and Health Health Services and First Aid Less than the 10 percent of the workforce was trained in first aid. Provide training in first aid to at least 10 percent of the workforce. For Training of First Aid the Compliance already proceed of 10 percent of workers trained like 104 persons, we have the Attendance List of all workers received the training. 30 Apr-18 Occupational Safety and Health Working Environment Temperature levels exceeded the recommended limits. Purchase additional fans. Ensure that all exhaust fans are properly functioning. Request quotes for the installation of a cooling system and analyse feasibility. Additional fans were purchased and installed on the floor. 31 Apr-18 Occupational Safety and Health Working Environment Noise levels exceeded the recommended limits. Reduce the volume of the The factory replaced some music in the workplace. Ensure parts of the sound system to that all sewing and pressing control the noise levels. machines are properly maintained to avoid additional noise. 32 Apr-18 Occupational Safety and Health Working Environment Light levels was below the recommended limits. Conduct an inspection to verify if all light are functioning in the workplace and repair the broken ones. Ensure that regular maintenance is performed. The factory replaced the deficient or missing bulbs to provide adequate lighting. 33 Apr-18 Occupational Safety and Health Emergency Preparedness Some fire extinguishers were not easily accessible. Provide OSH training for workers. Conduct regular inspection to ensure that fire extinguishers are not misplaced or obstructed. The factory conduct regular inspection to ensure that fire extinguishers are not misplaced or obstructed. Additional OSH training was provided for the OSH committee. 34 Apr-18 Occupational Safety and Health Emergency Preparedness Less than the 10 percent of the workforce was trained in firefighting. Provide training in firefighting to at least 10 percent of the workforce. 96 New employees were trained in fire fighting. 35 Apr-18 Occupational Safety and Health Emergency Preparedness Update the evacuation plan in the building and post on the floor. The evacuation plan in building 52 was updated and posted on the floor. 36 Apr-18 Occupational Safety and Health Emergency Preparedness The current evacuation plans in one building have not been updated to reflect the recently reorganized floor layout. Assessors observed that evacuation routes were obstructed. 0 37 Apr-18 Occupational Safety and Health Emergency Preparedness The floor layout should be revised to ensure that evacuation routes are not obstructed. Keep all flammable material away from possible sources of ignition. Train the workers on OSH requirements. Conduct Flammable material such as fabric were observed inside 1 electrical panel in one of the building. 38 130 Apr-18 Occupational Safety and Health Welfare Facilities Insufficient number of toilets. Reallocate some men's toilets for women. Build additional toilets to meet legal requirements. Keep the existing toilets properly maintained. The factory requested SONAPI authorization to build more toilets. 39 Apr-18 Occupational Safety and Health Welfare Facilities The results of the analysis of the drinking water revealed the presence of bacteria. The factory has a new water supplier and the results of the analysis of the drinking water confirmed that it was safe. 40 Apr-18 Occupational Safety and Health Health Services and First Aid The factory does not provide workers with free annual health checks. Share the results of the water test with the drinking water supplier and ensure that they take action to provide safe water. Identify potential new suppliers as possible alternatives. Conduct regular monthly test. Provide workers with free annual health checks. Keep adequate records. The factory started to provide annual medical checks to workers as required. 41 The factory revised its payroll procedure and the weekly rest days payment is now based on the average salary. The factory revised its payment procedures to ensure compliance with legal requirements. 12 Assessment April 2017 Apr-17 Compensation Paid Leave Payment for weekly rest days. Ensure that the weekly rest day payment is correct. Apr-17 Compensation Paid Leave Payment for legally mandated holidays. Revise payroll procedures to ensure compliance with legal requirements Apr-17 Compensation Social Security and Other Benefits Collecting and forwarding workers' contributions for social insurance funds to ONA. Revise payroll procedures to ensure compliance with legal requirements The factory revised its payroll procedures to ensure compliance with legal requirements. ONA payment is now done with base salary. 12 Apr-17 Compensation Social Security and Other Benefits Employer contribution to ONA. Revise payroll procedures to ensure compliance with legal requirements 12 Apr-17 Compensation Social Security and Other Benefits Registered with OFATMA for the maternity and health insurance. Apr-17 Compensation Social Security and Other Benefits Employer contribution to OFATMA for maternity and health insurance. Collecting and forwarding of workers' t ib ti andt forwarding OFATMA of Collecting workers' contributions to OFATMA. The factory revised its payroll procedures to ensure compliance with legal requirements. ONA payment is now done with base salary. Management completed the registration process to OFATMA. Registered with OFATMA for the maternity and health insurance. Management completed the registration process to OFATMA. 12 12 12 131 Apr-17 Contract and Human Resources Dialogue, Discipline and Disputes Bullying, harassment or humiliating treatment of workers. Provide training to both Haitian and foreign supervisors on the verbal abuse policy The factory conducted training for both Haitian and foreign supervisors on the verbal abuse policy. Training was also provided to workers. 20 Apr-17 Occupational Safety and Health Chemicals and Hazardous Substances Labelling of chemicals and hazardous substances. Conduct awareness training for all workers handling chemicals. A system should be put in place to avoid recurrence. The factory labelled all the chemicals containers and provided training to all workers using chemicals. 48 Apr-17 Occupational Safety and Health Chemicals and Hazardous Substances Chemical safety data sheets for all chemicals and hazardous substances in the workplace. Ensure that all required chemical safety data sheets for all chemicals and hazardous substances are available in the workplace. Chemical safety data sheets for all chemicals and hazardous substances are available in the workplace. 48 Apr-17 Occupational Safety and Health Chemicals and Hazardous Substances Assessing, monitoring, preventing and/or limiting workers' exposure to hazardous substances. Assess, monitor, prevent and/or limit workers' exposure to hazardous substances. The factory regularly assessing and monitor workers' exposure to hazardous substances. 12 Apr-17 Occupational Safety and Health Chemicals and Hazardous Substances Occupational Safety and Health Emergency Preparedness Provide adequate washing facilities or cleansing materials in the event of chemical exposure. The factory should trained additional workers in fire fighting. Apr-17 Occupational Safety and Health Emergency Preparedness Some firefighting equipment were not properly maintained. Ensure that all firefighting equipment are properly maintained and inspected. Washing facilities or cleansing materials in the event of chemical exposure are available. The factory trained additional workers in fire fighting. Based on the current number of workers, The compliance officer regularly verify the firefighting equipment. 48 Apr-17 Washing facilities or cleansing materials in the event of chemical exposure were not available in all areas where workers use h i lworkers to use the Training firefighting equipment Apr-17 Occupational Safety and Health Health Services and First Aid Annual medical checks for workers. Increase doctor's visit frequency to 3 visits a week and have doctors perform medical checks. The factory hired a doctor who conducts the medical checks on a regular basis. 48 Apr-17 Occupational Safety and Health Health Services and First Aid No medical checks are provided to workers within the first three months of hiring. The factory hired a doctor who conducts the medical checks on a regular basis. 12 Apr-17 Occupational Safety and Health Health Services and First Aid Increase doctor's visit frequency to 3 visits a week and have doctors perform medical checks. The factory does not provide free Increase doctor's visit health checks to workers who have frequency to 3 visits a week been exposed to work related and have doctors perform hazards. medical checks. The factory hired a doctor who conducts the medical checks on a regular basis. 48 12 12 132 Apr-17 Occupational Safety and Health Health Services and First Aid The factory has only 2 nurses. To comply with the Haitian Labour Code, the factory should have a permanent onsite medical service, with at least 5 nurses and 3 doctors' visits each week. Hire 2 additional nurses and increase doctor's visit frequency to 3 times a week. The factory hired a doctor who visit 3 times per week. 48 Apr-17 Occupational Safety and Health Health Services and First Aid The employer did not ensure that there were a sufficient number of readily accessible first aid boxes/supplies in the workplace. Ensure that all the first aid boxes/supplies in the workplace are readily accessible . All the first aid boxes/supplies in the workplace are readily accessible . 12 Apr-17 Occupational Safety and Health Health Services and First Aid Insufficient first-aid training for workers. Provide first-aid training for 10% of workers. 12 Apr-17 Occupational Safety and Health Welfare Facilities Insufficient number of Toilets. Increase the number of toilets. 12 Apr-17 Occupational Safety and Health Welfare Facilities Insufficient capacity of eating area. Increase the capacity of the easting area. 12 Apr-17 Occupational Safety and Health Worker Protection Workers using chemicals are not provided with personal protective clothing and equipment. Worker using chemicals should be provided with personal protective clothing and equipment. All workers using chemicals are provided with personal protective clothing and equipment. 48 Apr-17 Occupational Safety and Health Worker Protection Shock absorbing mats are missing for standing workers. Provide all standing workers with Shock absorbing mats All standing workers are provided with shock absorbing mats 12 Apr-17 Occupational Safety and Health Working Environment Workplace temperature and/or ventilation is no adequate. Ensure that workplace temperature and/or ventilation comply with recommended limits. Apr-17 Working Time Overtime Limits on overtime hours worked. Monitor and limit the number of overtime hours performed. The factory is monitoring the number of overtime hours performed to ensure that workers do not exceed 80 hours per trimester. 24 Apr-17 Working Time Regular Hours Daily break periods. Review the internal policies regarding break for pregnant women The factory reviewed the internal policies regarding break for pregnant women. Also all pregnant women were informed of this new policy 12 48 133 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Date of last two Better Work assessments: MGA Haiti S.A Port-au-Prince 1103 Sep-09 Jun-18 Feb-17 Advisory and Training Services 12-Mar-19 Factory visit to discuss the February 20-23 work stoppage with SOTA union members 7-Dec-18 Workshop on gender challenges in the workplace 5-Dec-18 Factory visit to do -Occupational Safety & Health training for Committee members and discuss improvement plan with compliance officer. 5-Dec-18 Training in Occupational Safety and Health (OSH) ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT DETAILS OF NON COMPLIANCE IMPROVEMENT PRIORITIES REMEDIATION EFFORTS MONTHS Assessment June 2018 Jun-18 Compensation Paid Leave The factory only paid 6 weeks for maternity leave payments instead of 12 weeks. Management is to re-engage and complete registration process with OFATMA for maternity and health in order to secure full benefit of 12 weeks for employees. 10 Jun-18 Compensation Social Security and Other Benefits The factory has not yet registered with OFATMA for maternity and health insurance. Management is to re-engage and complete registration process with OFATMA for maternity and health. 22 Jun-18 Compensation Social Security and Other Benefits The factory has not yet registered with OFATMA for maternity and health insurance. Management is to re-engage and complete registration process with OFATMA for maternity and health. 22 Jun-18 Contract and Human Resources Termination Insufficient number of days paid to workers for annual leave regardless of the duration of their employment. Ensure proper calculation of unused annual leave based on 1.25 day per month accumulation rate. Annual leave is earned based on based on 1.25 day per month accumulation rate. 10 Jun-18 Contract and Human Resources Termination Workers bonus payments upon termination are not based on 1/12 of their earnings for the current calendar year. Calculate bonus payments upon termination based on 1/12 of worker's earnings for the current calendar year. Workers terminated in July after recent assessment received 1/12th of total year to date gross earnings. 10 134 Jun-18 Contract and Human Resources Dialogue, Discipline and Disputes Allegation of verbal abuse reported that foreign managers shout at workers , hit the tables and throw the shirts on the ground and asked workers to pick them up. 1. Schedule and complete training for managers and supervisors on verbal abuse. 2. Assign responsible person to monitor behaviour Jun-18 Occupational Safety and Health OSH Management Systems The OSH committee did not hold a meeting since October 2017. 1. Appoint new OSH officer. 2 Resume regular meetings of OSH committee with documented minutes for newly elected OSH committee members in 2018 elections. Jun-18 Occupational Safety and Health OSH Management Systems The employer failed to provide the receipt of acknowledgement from OFATMA for the month of November 2017. Develop adequate document management system that could be available at any time for necessary internal consultation and upon request by appropriate 3rd party. Jun-18 Occupational Safety and Health OSH Management Systems OSH policy was not developed in consultation with workers and their representatives. 1. Discuss OSH policy with newly elected bipartite committee members as soon as reasonably possible for inputs and suggestions. 2. Document in meeting minutes and modify if necessary with top management signature. 10 Jun-18 Occupational Safety and Health Chemicals and Hazardous Substances The chemical inventory does not include all the locations even though assessors found that chemicals were stored in different places. Update and maintain a complete inventory of all chemicals used in factory premises with respective locations. 10 Jun-18 Occupational Safety and Health Chemicals and Hazardous Substances Assessors found one unidentified container of machine oil. Ensure proper labelling of all containers that store products used in operations. 10 Jun-18 Occupational Safety and Health Chemicals and Hazardous Substances No MSDSs were available for Airlubes and spot remover. Conduct assessment of inventory of all chemical products used in the spot cleaning and ensure all MSDS are available. No additional occurrences of verbal abuses have been reported. 10 10 Management maintains back up copies of accidents report submitted. Last advisory visit confirms MSDS's are posted. 10 10 135 Jun-18 Occupational Safety and Health Worker Protection Earplugs and proper masks were not available for workers . Ensure proper personal protection equipment are available including but not limited to earplugs, and proper masks. 10 Jun-18 Occupational Safety and Health Worker Protection Assessors observed exposed wires, electrical panel enclosed in a wooden box and electrical outlets without cover. 1. Ensure wires are adequately covered. 2. Ensure electrical panels are not enclosed in flammable materials. 10 Jun-18 Occupational Safety and Health Worker Protection One electrical panel was without appropriate safety warnings. Ensure appropriate safety warnings on electrical panels throughout the factory. Jun-18 Occupational Safety and Health Working Environment Workplace temperatures exceed 31 C in all sections of all buildings. 1. Use electrical exhaust fans or cooling system 2. Ensure that the air-flow to and from the fans is not blocked. 3 Monitor workplace temperature on a regular basis 94 Jun-18 Occupational Safety and Health Working Environment Insufficient lighting in some sections. Explore and adopt lighting improvement measures accordingly to stay within recommendations. 10 Jun-18 Occupational Safety and Health Welfare Facilities Eating area can accommodate only 50 percent of workforce. 1. Expand eating area for 100% of workers 107 Jun-18 Occupational Safety and Health Health Services and First Aid Arrange systematic medical checks for newly hired workers 22 Jun-18 Occupational Safety and Health Health Services and First Aid Arrange systematic medical checks for newly hired workers. 22 Jun-18 Occupational Safety and Health Health Services and First Aid Workers do not receive any medical checks within the first three months of being hired Out of 43 workers interviewed, 40 workers revealed that no health check was provided to them for the last twelve months. Insufficient medical personnel. Have a permanent onsite medical service, with at least 5 nurses and 3 doctors' visits per week. 107 Jun-18 Occupational Safety and Health Health Services and First Aid One first aid box was obstructed by sewing tables. Work with OSH delegates and ensure that first aid boxes are not obstructed. Safety warning is now posted. No additional obstruction was recorded during advisory visits. 22 136 Jun-18 Occupational Safety and Health Health Services and First Aid Documentation review showed that only 32 workers were trained in first aid for the last twelve months. Provide first aid training for 10 percent of the workforce, once per year. 10 Jun-18 Occupational Safety and Health OSH Management Systems Dust should not accumulate on the surfaces of electrical equipment and machines. Combustible materials like fabric waste, plastic or paper should not be scattered around the workplace. 1. Provide more efficient cleaning equipment for factory floor 2. Consider usage of vacuums over broom sticks to prevent Dust from accumulating 10 Jun-18 Occupational Safety and Health Worker Protection The employer does not provide trolleys or carts for lifting and moving heavy or bulky loads. Provides mechanical devices such as trolleys or carts for lifting and moving heavy or bulky loads. 10 Jun-18 Occupational Safety and Health Emergency Preparedness 1. Fire escape routes are not clearly marked. Keep escape routes clearly marked for both buildings 11 and 17. 22 Jun-18 Occupational Safety and Health Emergency Preparedness One electrical panel was enclosed in a wooden box Ensure that electrical panels are not enclosed in flammable material. Jun-18 Occupational Safety and Health Emergency Preparedness Several phones were charging in uncovered electrical outlets near flammable chemical such as thinner and blow out. Ensure proper storage of chemical away from potential sources of ignition. None of the electrical panels in building 17 mechanic shop is enclosed in a wooden box. 10 10 Assessment Feburary 2017 Feb-17 Compensation Premium Pay After a period of 6 consecutive days workers do not benefit from a weekly rest day paid. The factory must pay the day of Sunday after a period of 6 working days. No longer legally required Feb-17 Compensation Paid Leave Payment for legally mandated holidays is based on the minimum wages instead of worker's average earning. Adjust Payroll system to ensure payment for legally mandated holidays is accurate The changes have been made in the payroll system and payment for legally mandated holidays is based on worker's average earning. Feb-17 Compensation Paid Leave Payment for weekly rest days is based on the minimum wage instead of workers' average earning. Adjust payroll system to ensure that payment for weekly rest days is accurate. The changes have been made in the payroll system, payment for weekly rest days is based on workers' average earning. 137 Feb-17 Compensation Social Security and Other Benefits The employer is not affiliated with OFATMA for maternity and health insurance services. Register with OFATMA for maternity and health insurance services Feb-17 Compensation Social Security and Other Benefits The employer is not affiliated with OFATMA for maternity and health insurance services. Register with OFATMA for maternity and health insurance services Feb-17 Compensation Social Security and Other Benefits ONA payments are based on the worker's minimum wages instead of basic salary. Ensure that ONA payments are based on the basic salary instead of worker's minimum wages. The changes are made to calculate from basic salary. Feb-17 Compensation Social Security and Other Benefits Collecting and forwarding worker's contributions for social insurance funds to ONA. Ensure that ONA payment is based on the basic salary instead of worker's minimum wages. The changes are made from minimum salary to basic salary. Feb-17 Contract and Human Resources Employment Contracts Missing terms and conditions of employment in written employment contracts. Review employment contract to ensure compliance with legal requirements. The employment contract has been revised with the term and specifications. Feb-17 Occupational Safety and Health Chemicals and Hazardous Substances Labelling of chemicals and hazardous substances in the mechanic room. Label all containers and provide posters on labelling chemicals substances. Incorporate the importance of labelling containers into the training on chemical substances. Monitor the labelling of containers. have someone in charge for transferring the chemicals. Training was delivered to workers in spot cleaning area. The compliance officer put all labelling in local language. A daily inspection is done by the compliance officer. Feb-17 Occupational Safety and Health OSH Management Systems No mechanisms to ensure cooperation between workers and management on OSH matters. Ensure that the factory has an active OSH committee which meets at least once a month. All committee members have been trained. The factory conducts an occupational safety and health assessment every month. Feb-17 Occupational Safety and Health Emergency Preparedness A fire extinguisher was missing in the boiler room and also no proof of regular maintenance was provided. Increase the frequency of inspections of fire extinguishers in all buildings. Replace missing fire extinguishers. Keep a stock of additional fire extinguishers for use in an emergency. The missing fire extinguisher has been replaced and an inspection sheet is available. Moreover, a stock of additional fire extinguishers is available to be used in case of emergency. 138 Feb-17 Occupational Safety and Health Emergency Preparedness Several escape routes were obstructed with fabric bundles. Ensure that the aisles in the sewing lines remain unobstructed during working hours, including overtime 0 Feb-17 Occupational Safety and Health Health Services and First Aid No health checks for workers who are exposed to work related hazards. Provide medical checks to workers who have been exposed to work related hazard twice a year. Doctor has already made a general medical check for the employees of the chemical department, including: Analysis, Scanner X-Ray and provided them medications. Feb-17 Occupational Safety and Health Health Services and First Aid Annual medical checks for workers not performed. Ensure Annual medical checks is provided to all workers. Paraclinical examinations is being conducted by the doctor of the factory until all workers in the factory are checked. Feb-17 Occupational Safety and Health Worker Protection No appropriate PPE was provided to workers using thinner. Provide appropriate PPE and conduct training for all workers using chemicals. The training was done for workers in the spot cleaning and PPE have been provided. Feb-17 Occupational Safety and Health Worker Protection Several electrical boxes with exposed wires was observed during the assessment Ensure that electrical wires and equipment are properly installed and maintained. The factory completed the installation of electrical cord covers. Feb-17 Occupational Safety and Health Working Environment The temperatures in Building 17, sewing and pressing section exceed BW recommended limit of 30 C Improve the temperature levels in the noted areas. Feb-17 Occupational Safety and Health Welfare Facilities Insufficient toilet for men and women Ensure that the factory has at least 37 functioning toilets for women and 14 functioning toilets for men. Sonapi has already begun with the construction of 14 new toilets. Feb-17 Occupational Safety and Health Welfare Facilities The eating area can only accommodate a small percentage of the workforce. Ensure that the eating area can accommodate all workers The factory has already built a new cafeteria in front of building 11, it can accommodate all workers during the lunch time. Feb-17 Occupational Safety and Health Health Services and First Aid The factory has insufficient medical staff. Hire additional medical staff, at least 4 nurses and 3 doctor's visit per week. The doctor makes 3 visit per week in the factory. 139 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Date of last two Better Work assessments: Pacific Sports Haiti S.A. Port-au-Prince 1976 Nov-09 Jul-17 Aug-18 Advisory and Training Services 13-Mar-19 Advisory visit to follow up on the reinstatement of the union leader. Review the induction training and follow up on the improvement plan. OSH factory tour. PICC meeting about the training needs 13-Mar-19 Meeting to present the new OSH checklist and discuss about the training needs 13-Dec-18 Training in Risk Management & Control 7-Dec-18 Workshop on Gender challenges at the workplace. 5-Dec-18 Advisory visit to investigate suspension case of union leader and Management meeting Meeting with the bipartite committee 5-Dec-18 Meeting to set goals for the new year. 29-Nov-18 Meeting to present:all hazard sign to the members and discuss about Management, workers rights and responsibilities 27-Nov-18 Training in Sexual Harassment in the events of Share Hope 26-Oct-18 Meeting to discuss the following points:Unblock emergency exits also receive complaints and suggestion from committee members 25-Oct-18 5-Jun-18 1-Jun-18 Advisory visit to review the training plan and introduction to the online training management system. Introduction to the new online progress report. PICC meeting. OSH factory tour. Training in Supervisory Skills (SST) Training in Leadership Skills ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT Aug-18 Compensation Overtime Wages Workers are not compensated 50% above the normal wage as a direct result of overtime hours. Pay workers 50% above the normal wage for all ordinary overtime hours worked. Aug-18 Compensation Social Security and Other Benefits Worker contribution to ONA not submitted on time. Ensure that workers' contribution are collected and forwarded to ONA on time. DETAILS OF NON COMPLIANCE IMPROVEMENT PRIORITIES REMEDIATION EFFORTS MONTHS Assessment August 2018 8 Payments are submitted within the 10 business days of each month for the previous month. 8 140 Aug-18 Compensation Social Security and Other Benefits Employer contribution to ONA. Ensure that employers' contribution are forwarded to ONA on time. Aug-18 Compensation Social Security and Other Benefits The factory is not registered with OFATMA for maternity and Health insurance. Register with OFATMA for maternity and health insurance services. 20 Aug-18 Compensation Social Security and Other Benefits Collect and forward workers' contributions to OFATMA. Register with OFATMA. Collect and forward workers 'contributions to OFATMA for maternity and health insurance services. 20 Aug-18 Compensation Termination The payment for the notice period is based on the minimum wage. Ensure that The payment for the notice period is calculated on workers' average earnings. Aug-18 Occupational Safety and Health Chemicals and Hazardous Substances MSDS were not available for chemical and hazardous substances such as paints, radiator coolant, Max cleaner. Identify a person responsible for chemical management. Prepare and post MSDS where chemicals are used. 8 Aug-18 Occupational Safety and Health Emergency Preparedness One fire extinguisher was obstructed in the stock room during the assessment visit. Mark all spaces that should not be obstructed in the workplace. Ensure that access to fire extinguishers remain unobstructed in the workplace. 53 Aug-18 Occupational Safety and Health Emergency Preparedness Escape routes in packing section of building 27 and in the cutting section of building 26 were not clearly marked. Verify the evacuation plan and mark all the escapes route in the workplace. Aug-18 Occupational Safety and Health Emergency Preparedness Routes were obstructed by production materials in some aisles of building 25 and by heavy lifting support equipment in building 26. Conduct a root cause analysis. Have someone in charge of verifying and ensuring that the aisles remain unobstructed during working hours, including overtime. Payments are submitted within the 10 business days of each month for the previous month. Adjustment has been made in the payroll and the notice period is calculated on workers' average earnings. Escape routes in packing section of building 27 and in the cutting section of building 26 now are clearly marked. 8 8 8 20 141 Aug-18 Occupational Safety and Health Health Services and First Aid Insufficient medical staff. Ensure that the factory has a permanent onsite medical staff, with at least 8 nurses and 3 doctor's visits per week. 47 Aug-18 Occupational Safety and Health Worker Protection Workers assigned to the spot cleaning area to do inspection were not using proper PPE. Provide proper PPE to workers in the spot cleaning. 8 Aug-18 Occupational Safety and Health Worker Protection Battery terminals in the generator room were missing the insulation cover. Install the insulation cover and specify who conduct daily weekly checks and include this in the system of daily weekly checks. 8 Aug-18 Occupational Safety and Health Working Environment Temperature exceed Better Work recommended limit of 30 C in all sections. Improve the temperature levels in all sections. Then conduct regular measurement of temperature. 70 Aug-18 Occupational Safety and Health Working Environment Workplace lighting is below BW recommended limit in Sewing, packing and quality sections. Ensure the lighting is adequate and adapted to worker's needs. Jul-17 Occupational Safety and Health Wage Information, Use and Deduction The payroll is not accurate because the number of overtime hours in the payroll records did not match the attendance records. Ensure that information in the payroll is accurate. Jul-17 Compensation Paid Leave Payment for legally mandated holidays is based on the minimum wages instead of worker's average earning. Adjust Payroll system to ensure payment for legally mandated holidays is based on worker's average earning. Jul-17 Compensation Social Security and Other Benefits The employer is not affiliated with OFATMA for maternity and health insurance services (workers' contributions). Register with OFATMA for maternity and health insurance services. The electrician is in charge for the regular maintenance of the light and the Compliance Staff is in a charge to conduct l t Assessment July 2017 Payment for legally mandated holidays is based on worker's average earning. 6 142 Jul-17 Compensation Social Security and Other Benefits The employer is not affiliated with OFATMA for maternity and health insurance services (employer's contributions). Register with OFATMA for maternity and health insurance services. Collect and forward workers contribution to OFATMA. Jul-17 Occupational Safety and Health Emergency Preparedness In the fabric warehouse of Building 25, access to several fire extinguishers were obstructed by boxes. Near Building 27, access to one fire extinguisher was also obstructed by boxes. Assign someone to do the inspection of the fire extinguishers on a regular basis. Do a root cause analysis to find out why several fire extinguishers are obstructed. Provide training to the workers on firefighting equipment. Jul-17 Occupational Safety and Health Emergency Preparedness 80 percent of the aisles are blocked by trolleys in the fabric warehouse of Building 25. Do a root cause analysis on why the aisles are blocked by trolleys. Have someone in charge to monitor that the aisles remain free. Jul-17 Occupational Safety and Health Working Environment Temperature exceed Better Work recommended limit of 30 C in all sections. Improve the temperature levels in the noted areas. Jul-17 Occupational Safety and Health Working Environment Noise levels in the sewing section of building 8 exceed 90 dB. identify noise producer source and replace it. Provide PPE to the workers if noise levels can not be reduced. Jul-17 Occupational Safety and Health Emergency Preparedness An electrical cabinet in the fabric warehouse of Building 25 was blocked by cardboard boxes, which can be a potential fire hazard. identify a place to put the cardboard boxes. Ensure that the electrical cabinet is unobstructed. Jul-17 Occupational Safety and Health Health Services and First Aid Annual medical checks for workers. Ensure Annual medical checks is provided to all workers. The boxes have been removed, also 2 persons were designated to conduct the daily inspection of the fire extinguishers. New fans and extractors have been added. The boxes have been removed. 143 Jul-17 Occupational Safety and Health Health Services and First Aid Onsite medical facilities and staff. The factory has 5 nurses and 3 doctor's visits each week. Hire additional medical staff, at least 8 nurses and 3 doctor's visit per week. The management is currently recruiting 2 additional nurses. 144 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Date of last two Better Work assessments: Palm Apparel S.A. Port-au-Prince 1612 Nov-09 Jul-17 Sep-18 Advisory and Training Services 27-Mar-19 Factory visit to conduct a session on BW portal with the compliance team. OSH Factory tour. Union Interview. Review payment of social security 7-Dec-18 Workshop on Gender challenges at the workplace. 6-Dec-18 Factory visit to organise a session on the online training management system and the new online progress report. OSH factory tour. Bipartite committee meeting. 6-Dec-18 Meeting to present the challenges and discuss about perspectives for the new year 14-Nov-18 Building bridges workshop for national partners 20-Sep-18 Training in Sexual Harassment Awareness and Prevention Supervisors & Middle Management 20-Sep-18 Training in Sexual Harassment Awareness and Prevention Workers 29-Jun-18 Training in Chemical Management System ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT DETAILS OF NON COMPLIANCE IMPROVEMENT PRIORITIES REMEDIATION EFFORTS MONTHS Meeting was held with management, workers' contribution are collected and calculate on basic salary but we have to introduce the amount of incentive of the week. 96 Assessment September 2018 Sep-18 Compensation Social Security and Other Benefits Late and inaccurate payment of workers contributions for ONA. Ensure that workers' contribution are collected and forwarded to ONA on time and calculate this amount based on basic salary instead of the minimum wage. Sep-18 Compensation Social Security and Other Benefits Late and inacurate payment of employer contributions for ONA. Submit ONA payments on time and calculate this amount based on basic salary instead of the minimum wage. 96 Sep-18 Compensation Social Security and Other Benefits Payment of employer's contribution to OFATMA for the maternity and health insurance is innacurate. Forward 3 percent of workers' base salary to OFATMA for maternity and health insurance. 25 Sep-18 Compensation Social Security and Other Benefits Payment of workers' contribution to OFATMA for maternity and health insurance is innacurate. Collect and forward 3 percent of workers' base salary to OFATMA for maternity and health insurance. 25 145 Sep-18 Occupational Safety and Health Chemicals and Hazardous Substances Unlabelled containers of oil and water being used in the workplace. Ensure that all hazardous and chemicals substances used in the workplace are properly labeled. 25 Sep-18 Occupational Safety and Health Chemicals and Hazardous Substances No MSDSs were posted where chemicals are stored and used. Prepare and post MSDS where chemicals are used. 25 Sep-18 Occupational Safety and Health Chemicals and Hazardous Substances Management did not provide proper protective equipment in the spot cleaning area. Ensure that all PPE are available in the workplace. 7 Sep-18 Occupational Safety and Health Worker Protection Management did not provide proper dust masks for workers in the sewing floor. Provide dust Mask to workers in the sewing floor. 7 Sep-18 Occupational Safety and Health Worker Protection Management did not provided evidences of training performed on the use of personal protective equipment and machines. Conduct additional training on the wearing of PPEs 7 Sep-18 Occupational Safety and Health Worker Protection Electrical panel missing cover in the generator room. Ensure that all electrical panels are closed and properly maintained. 7 Sep-18 Occupational Safety and Health Worker Protection Several electrical boxes are missing hazard sign in floor 3, 4 and 5. Identify electrical installations requiring warning signs and Post corresponding signs 7 Sep-18 Occupational Safety and Health Working Environment Temperature exceed Better Work recommended limit of 30 C in all sections. Ensure that the temperature does not exceed the recommended limit. 7 Sep-18 Occupational Safety and Health Working Environment Workplace lighting is below BW recommended limit in sewing and quality sections of floor 1,2.. Ensure the lighting is adequate and adapted to worker's needs. 25 Sep-18 Occupational Safety and Health Welfare Facilities Insufficient number of toilets. Increase the number of toilets. 25 146 Sep-18 Occupational Safety and Health Health Services and First Aid The employer did not provide annual medical checks for workers. Provide annual medical checks for workers. 25 Sep-18 Occupational Safety and Health Health Services and First Aid The employer did not provide medical checks for workers within the first three months of hiring. Provide health checks at no cost for workers within the first three months of hiring. 7 Sep-18 Occupational Safety and Health Health Services and First Aid The employer did not provide health checks for workers who are exposed to work-related hazards twice a year. Provide health checks twice a year at not cost for workers who are exposed to work related hazards 7 Sep-18 Occupational Safety and Health Health Services and First Aid Insufficient medical staff Hire the required medical staff. 7 Sep-18 Occupational Safety and Health Health Services and First Aid Products are missing in all firstaid boxes. Equip all first aid boxes and define responsibility for refillling them. 25 Sep-18 Occupational Safety and Health Emergency Preparedness One fire extiguisher was overcharged another one was not easily accessible. Ensure that access to fire extinguishers remain unobstructed in the workplace. Specify who conduct daily weekly checks . 7 Sep-18 Occupational Safety and Health Emergency Preparedness The evacuation plan is not accurate. Update the evacuation plan. 7 Sep-18 Occupational Safety and Health Emergency Preparedness Assessors observed escape routes blocked by boxes of finished goods and other materials in floors 1,2 and 3. Identify a space to store finished goods and materials. Then assign someone to follow-up on a monthly basis. 90 Sep-18 Working Time Regular Hours Working time records are manually reported. Have an accurate attendance recording system. Use a form to request workers to work overtime 91 Sep-18 Child Labour Child Labourers workers files missing ID document with picture. Improve the recruitment procedure to ensure that reliable documents & techniques are used to verify the age of workers. 7 Assessment July 2017 147 Jul-17 Compensation Premium Pay Payment for regular hours worked on legally mandated holidays is based on the minimum wages instead of worker's average earning. Adjust Payroll system to ensure payment for regular hours worked on legally mandated holidays is based on worker's average earning. Payroll system adjust for this point. Payment for regular hours worked on legally mandated holidays is based on average earning. Jul-17 Compensation Paid Leave Payment for legally mandated holidays is based on the minimum wages instead of worker's average earning. Ensure payment for legally mandated holidays is based on worker's average earning. The payment for legally mandated holidays is based on average earning. Jul-17 Compensation Social Security and Other Benefits Employer Contribution to ONA. ONA contributions is based on the minimum wage instead of the base salary Revised payroll procedure to ensure that ONA payment is based on the basic salary instead of worker's minimum wage. Jul-17 Compensation Social Security and Other Benefits Collecting and forwarding worker's contributions for social insurance funds to ONA. Ensure that ONA payment is based on the basic salary instead of worker's average earnings. Jul-17 Occupational Safety and Health Chemicals and Hazardous Substances Labeling of chemicals and hazardous substances in the mechanic room Label all containers and provide posters on labeling chemicals substances - Incorporate the importance of labeling containers into the training on chemical substances - Monitor the labeling of containers Jul-17 Occupational Safety and Health OSH Management Systems The temperatures exceed BW recommended limit of 30 C in Building 2, 3 and 4, packing, sewing and inspection section. Improve the temperature levels in the noted areas. Jul-17 Occupational Safety and Health Welfare Facilities Insufficient number of toilets Increase the number of toilets. Jul-17 Occupational Safety and Health Welfare Facilities The eating area located at Thor can only accommodate a small percentage of the workforce Ensure that the eating area can accommodate all workers. Jul-17 Occupational Safety and Health Health Services and First Aid Onsite medical facilities and staff.The factory has 4 nurses and 3 doctor's visits per week. Hire additional medical staff, at least 7 nurses and 3 doctor's visit per week. Training has been conduct internally by H & S Responsible for mechanic department Request invoice for additional benches in order to accommodate more workers in the eating area 148 Jul-17 Occupational Safety and Health Emergency Preparedness Several escape routes were obstructed by boxes of finished goods on floors 2 and 5. Identify a space to store finished goods and materials. Then assign someone to follow-up on a monthly basis. Jul-17 Working Time Overtime No Authorization from the Departement of Labour for overtime Requested and obtained authorization from MAST before working overtime. Jul-17 Compensation Social Security and Other Benefits Employer contribution to OFATMA for maternity and health insurance. The factory collect and forward 2 percent of the worker's base salary Collect and forward 3 percent of worker's average earnings to OFATMA for maternity and health insurance. Jul-17 Compensation Social Security and Other Benefits Collect and forward worker's contribution to OFATMA for maternity and health insurance. Ensure that 3 percent of worker's average earnings is collected and forwarded to OFATMA for maternity and health insurance. -Conduct awareness training for all workers - One person per floor in charge of the daily inspection Request of authorization has been sent to MAST. Based on the new law, the Department of labour must advise on the necessary authorizations. 149 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Date of last two Better Work assessments: Premium Apparel S.A Port-au-Prince 1855 Oct-09 Aug-17 Aug-18 Advisory and Training Services Factory visit to discuss the improvement plan with management . 20-Mar-19 OSH factory tour : chemicals and emergency preparedness 3) Session about BW portal and progress report 1 with the compliance team 28-Jan-19 Training in Respectful Workplace Program 13-Dec-18 Training in Risk Management & Control 10-Dec-18 Factory visit to Review the improvement plan. Session with the compliance team on the new progress report 3) OSH factory tour 4-Dec-18 Training of Trainer supervisory Skills (ToT SST) 1-Dec-18 Training in Chemical Management System 14-Nov-18 Building bridges workshop for national partners ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT DETAILS OF NON COMPLIANCE IMPROVEMENT PRIORITIES REMEDIATION EFFORTS MONTHS Assessment August 2018 Aug-18 Compensation Social Security and Other Benefits Late and inacurate payment of employer contributions for ONA. Ensure that employer's contribution are based on workers' base salaries then collected and forwarded to ONA on time. 31 Aug-18 Compensation Social Security and Other Benefits Late and inacurate payment of workers contributions for ONA. Submit ONA payments on time and calculate this amount based on base salary instead of the minimum wage. 31 Aug-18 Compensation Social Security and Other Benefits The statement of contribution to OFATMA for work related accident was not available. Ensure that the amount declared to OFATMA for work related accident match the amount received by the workers for the previous fiscal year. 31 150 Aug-18 Compensation Social Security and Other Benefits Payment of employer's contribution to OFATMA for the maternity and health insurance is innacurate. Forward 3 percent of workers' base salary to OFATMA for maternity and health insurance. 31 Aug-18 Compensation Social Security and Other Benefits Payment of workers' contribution to OFATMA for maternity and health insurance is innacurate. Collect and forward 3 percent of workers' base salary to OFATMA for maternity and health insurance. 31 Aug-18 Contract and Human Resources Employment Contracts The employment contracts did not specify the terms and conditions of employment Employment contracts must also specify nature of work, working hours, rest periods, wage, place of work, term of employment. 7 Aug-18 Contract and Human Resources Employment Contracts The apprentice contracts are not registered and forwarded to the Ministry of Labor as prescribed in the Haitian Labor Code. Register the apprentice contracts to the Ministry of labor as prescribed in the Haitian Labor Code. 7 Aug-18 Occupational Safety and Health Chemicals and Hazardous Substances One unlabelled container of machine oil was observed in the mechanic shop. Ensure that all hazardous and chemicals substances used in the workplace are properly labeled. 7 Aug-18 Occupational Safety and Health Chemicals and Hazardous Substances No MSDSs were posted where chemicals such as propane gas and special water used for batteries are stored and used. Prepare and post MSDS where chemicals are used. Aug-18 Occupational Safety and Health Chemicals and Hazardous Substances Management did not isolate the use of chemicals and did not install exhaust ventilation. Improve isolation from the chemical and have a separate room for spot cleaning. 7 Aug-18 Occupational Safety and Health Emergency Preparedness Two fire extinguishers were missing, one was found overcharged and another one was obstructed. Ensure that access to fire extinguishers remain unobstructed in the workplace and the fire extinguishers are properly maintained. 22 Aug-18 Occupational Safety and Health Emergency Preparedness Assessors observed escape routes blocked by boxes in Maton. Identify a space to store finished goods and materials. Then assign someone to follow-up on a monthly basis. 41 The compliance officer is in charge of weekly check and MSDS for all hazardous chemicals used in the work place are available. 25 151 Aug-18 Occupational Safety and Health Health Services and First Aid The employer did not provide health checks for workers who are exposed to work-related hazards twice a year. Provide health checks twice a year at not cost for the workers who are exposed to work related hazards. 7 Aug-18 Occupational Safety and Health Health Services and First Aid The employer did not provide medical checks for workers within the first three months of hiring. Provide health checks at not cost for workers within the first three months of hiring. 89 Aug-18 Occupational Safety and Health Health Services and First Aid The employer did not provide annual medical checks for workers. Provide health checks at not cost for the workers. 89 Aug-18 Occupational Safety and Health Health Services and First Aid Insufficient medical staff. Hire the required quantity of nurses as described in the labor code. 89 Aug-18 Occupational Safety and Health OSH Management Systems The factory did not provide documented evidence of an internal assessment report for general occupational and health issues in the factory. Conduct a general OSH assessment on a monthly basis. 7 Aug-18 Occupational Safety and Health OSH Management Systems Declare accidents to OFATMA on a monthly basis. 7 Aug-18 Occupational Safety and Health OSH Management Systems The employer did not submit records of work-related accidents and diseases to OFATMA. OSH policy has not been developed in consultation with workers and their representatives. Consult with worker representatives to make necessary adjustment in the policy. 7 Aug-18 Occupational Safety and Health Working Environment The level of dust in the workplace accumulates on the machines including fans and on the electrical equipment. Hire additional cleaners and clean more regularly 7 Aug-18 Occupational Safety and Health Working Environment Workplace temperature exceed BW recommended limit of 30 C in all sections. Ensure that the temperature does not exceed the recommended limit. 35 Aug-18 Occupational Safety and Health Welfare Facilities Insufficient number of toilets. Increase the number of toilets. 22 Aug-18 Occupational Safety and Health Welfare Facilities Clorox and/or hand sanitizers were being provided to workers instead of soap. Ensure that soap is available. Management has provided liquid soap and the compliance officer is in charge of the daily-weekly checks. 7 152 Aug-18 Occupational Safety and Health Worker Protection Standing workers in the inspection sections of both buildings were not provided with foot rests or shock absorbing mats. Provide anti fatigue mats for standing workers Management has provided new anti fatigue mats for standing workers . 7 Aug-18 Occupational Safety and Health Worker Protection Management did not provide proper mask to workers using chemicals in the inspection sections. Provide proper mask to workers. Management has provided proper mask to workers using chemicals in the inspection sections. 19 Aug-18 Working Time Leave Breastfeeding break is not systematically granted. Give workers who are breast feeding children the required time for breastfeeding with full pay. A meeting was held with the supervisors and breastfeeding women are informed regarding their rights. 7 Aug-18 Working Time Overtime The factory did not show evidence of consent from the workers to perform the overtime. Use a form to request overtime from workers which includes the number of hours required & a space for worker signature. 22 Aug-18 Freedom of Association and Collective Bargaining Interference and Discrimination Termination or non-renewal of worker's employment contracts due to union membership or activities. Reinstate the 9 terminated workers. 7 Aug-18 Freedom of Association and Collective Bargaining Union Operations The employer did not provide the trade unions the necessary access from one building to another. Update the internal policies regarding freedom of association and allow union representatives to participate in union activities during non working hours. 7 Aug-17 Compensation Social Security and Other Benefits Late and inaccurate payment of employer contributions to ONA. Submit ONA payments on time and calculate this amount based on average earnings instead of the minimum wage. Aug-17 Compensation Social Security and Other Benefits Late and inaccurate payment of workers contributions to ONA. Ensure that workers' contribution are collected and forwarded to ONA on time and calculate this amount based on base salary instead of the minimum wage. Assessment August 2017 153 Aug-17 Compensation Social Security and Other Benefits No evidence of registration for work related accident insurance available. Ensure employer contribution to OFATMA for work-related accident insurance is 3 percent of workers' base salary. Aug-17 Compensation Social Security and Other Benefits Payment of employer's contribution to OFATMA for the maternity and health insurance is inaccurate. Forward 3 percent of workers' base salary to OFATMA for maternity and health insurance. Aug-17 Compensation Social Security and Other Benefits Payment of workers' contribution to OFATMA for the maternity and health insurance is inaccurate. Collect and forward 3 percent of workers' base salary to OFATMA for maternity and health insurance. Aug-17 Occupational Safety and Health Chemicals and Hazardous Substances Inadequate storage of chemicals and hazardous substances. Define a storage place for each chemical. Ensure the written instructions on MSDS are available in the storage place. Aug-17 Occupational Safety and Health Worker Protection Workers using chemicals without appropriate mask. Provide all necessary personal protective clothing and equipment. Aug-17 Occupational Safety and Health Working Environment The temperature level exceed BW recommended limit of 30 C. Improve the temperature levels in the noted areas. Aug-17 Occupational Safety and Health Welfare Facilities Insufficient number of toilets. Increase the number of toilet. Aug-17 Occupational Safety and Health Health Services and First Aid Medical checks are not systematically provided for workers upon hiring. Ensure medical checks are provided to new workers within the first three months of hiring. The factory has started to provide systematic health checks to new workers within the first three months of hiring Aug-17 Occupational Safety and Health Health Services and First Aid Annual medical checks not systematically provided for workers. Ensure annual medical checks are provided to all workers. The factory has started to provide annual medical checks to all workers. Aug-17 Occupational Safety and Health Health Services and First Aid insufficient medical staff. Hire additional medical staff, at least 8 nurses and 3 doctor's visit per week. Aug-17 Occupational Safety and Health Emergency Preparedness Firefighting equipment not properly maintained. Ensure that the workplace has adequate fire-fighting equipment. Assign someone to monitor firefighting equipment. Keep an inspection record. The chemical concerned, Blow out, has been removed from the supervisor's room. An OSH officer has been assigned to monitor firefighting equipment. 154 Aug-17 Occupational Safety and Health Emergency Preparedness Escape routes blocked by boxes of finished goods and other materials. Assign someone for verifying and ensuring that the aisles in the sewing lines remain unobstructed during working hours, including overtime. Aug-17 Occupational Safety and Health Chemicals and Hazardous Substances Missing chemical safety data sheets for all chemicals and hazardous substances in the workplace. Assign someone in charge for collecting MSDS when new chemicals are used. Post the MSDS in appropriate places. Conduct regular checks about the MSDS. Aug-17 Occupational Safety and Health Chemicals and Hazardous Substances Missing washing facilities or cleansing materials in the event of chemical exposure. Provide adequate washing facilities and cleansing materials in the event of exposure to hazardous chemicals. Aug-17 Working Time Regular Hours Regular daily and/or weekly working hours exceed the legal limit. Ensure regular daily and weekly working hours do not exceed the legal limit. Aug-17 Working Time Regular Hours No authorization from the Department of Labour before working at night. Obtain authorization from the Department of Labour before working at night. Based on the new law it is no longer a compliance point. Aug-17 Working Time Overtime The factory exceeded the legal limits on overtime hours worked in the packing section. Respect the legal overtime limit. Based on the new law it is no longer a compliance point. Aug-17 Working Time Overtime No authorization for performing overtime was provided by management during the time of the assessment. Request authorization of MAST to perform overtime work. Based on the new law it is no longer a compliance point. Aug-17 Working Time Overtime Management was unable to share any form of consent from the workers to perform overtime. Ensure that overtime work is voluntary. Aug-17 Occupational Safety and Health Emergency Preparedness Electrical box obstructed by flammable materials such as fabric cartons in the workplace. Ensure that flammable materials are safely stored. The missing water bottles have been replaced. Checklist has been updated to ensure that electrical boxes remain unobstructed. 155 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Date of last two Better Work assessments: Quality Sewing Manufacturing S.A Port-au-Prince 464 Oct-09 Sep-18 Apr-17 Advisory and Training 14-Mar-19 7-Dec-18 6-Oct-18 6-Oct-18 29-Jun-18 10-Jun-18 Factory visit to discuss on factory's updates and the Improvement plan remediation.Meeting with the unions on IR relations with management. Reflection Workshop on Women's Challenges in the Workplace. Factory visit to discuss on OSH management system and specifically documents to elaborate and to update the existing ones. Occupational Safety and Health training. Chemical Management System training. PICC meeting to present the updated OSH checklist. ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT Sep-18 Compensation Overtime Wages Sep-18 Compensation Wage Information, Use and Deduction Inaccuracy of time records. Ensure that time record system is accurate. Sep-18 Compensation Paid Leave Sep-18 Compensation Social Security and Other Benefits Calculation for sick leave was not based on average daily earnings during the previous 3 months of work. Late ONA payment. Calculate for sick leave payment based on average daily earnings during the previous 3 months of work. Pay ONA on time. 15 Sep-18 Compensation Social Security and Other Benefits Late ONA payment. Pay ONA on time. 15 Sep-18 Compensation Social Security and Other Benefits Payment for OFATMA work related accident was overdue. 15 Sep-18 Compensation Social Security and Other Benefits The employer only pays 2 per cent of workers' minimum wage instead of 3 per cent of workers' basic salary to OFATMA for maternity and health insurance. Complete the payment for OFATMA work related accident Forward 3 percent of worker's basic salary to OFATMA maternity and health insurance as employer's contribution. Sep-18 Compensation Social Security and Other Benefits Factory collected 2 per cent of workers' minimum wage instead of 3 per cent of workers' basic salary for OFATMA maternity and health insurance. Collect 3 percent of worker's basic salary for OFATMA maternity and health insurance as workers' contribution. 15 Sep-18 Contract and Human Resources Employment Contracts Worker's contract is missing hours of work and amounts of pay. Include the hours of work and the payment in the workers' contracts. 6 DETAILS OF NON COMPLIANCE IMPROVEMENT PRIORITIES REMEDIATION EFFORTS MONTHS Assessment September 2018 Overtime hours not reported in the Report and compensate all payroll records and not overtime hours worked. compensated. 15 15 156 Sep-18 Occupational Safety and Health OSH Management Systems OSH assessment reports are not performed on a regular basis. Perform an OSH assessment on a regular basis. 87 Sep-18 Occupational Safety and Health OSH Management Systems The employer has not developed any mechanism to ensure cooperation on OSH matters. Conduct regular meeting on OSH. 6 Sep-18 Occupational Safety and Health OSH Management Systems OSH policy is not signed by top management and was not developed in consultation with workers' representatives. Update the OSH policy in consultation with worker representatives. 6 Sep-18 Occupational Safety and Health Chemicals and Hazardous Substances Inventory of chemicals and hazardous substances not available. Ensure that the inventory of chemicals and hazardous substances used in the workplace is available. 87 Sep-18 Occupational Safety and Health Chemicals and Hazardous Substances Unidentified bottles of thinner in the electronic workshop and in the mechanic workshop. Identify all container of chemicals and hazardous substances used in the workplace. 87 Sep-18 Occupational Safety and Health Chemicals and Hazardous Substances chemicals and hazardous substances are improperly stored. Store the chemicals in an adequate location. Sep-18 Occupational Safety and Health Chemicals and Hazardous Substances MSDS were unavailable for several Ensure that MSDS are chemicals used in the workplace. available for all chemical used in the workplace. 87 Sep-18 Occupational Safety and Health Chemicals and Hazardous Substances No eye washing facilities in the electronic workshop where chemicals are used. Install an eye washing facility in all area where chemical and hazardous substances are used. 6 Sep-18 Occupational Safety and Health Worker Protection No proper gloves and goggles for workers in the mechanic shop. Provide the necessary personal protective equipment to workers. 6 Sep-18 Occupational Safety and Health Worker Protection No evidence of training provided to workers to properly use personal protective equipment and machines. 87 Sep-18 Occupational Safety and Health Worker Protection No foot rests or shock absorbing mats for some standing workers in inspection section. Train the workers on the use of use of personal protective equipment and machine. Keep adequate training records. Provide foot rests or shock The factory provided shock absorbing mats to standing absorbing mats to the workers. standing workers. Sep-18 Occupational Safety and Health Worker Protection About 30 per cent of the sewing machines were missing finger guards, eye guards and pulley guards. Equip all the sewing machines with necessary guards. 87 Sep-18 Occupational Safety and Health Worker Protection Uncovered electrical boxes with exposed wires and uncovered electrical outlets in the main building. Maintain the wiring and cable system. Properly cover all the electrical panels. 15 6 157 Sep-18 Occupational Safety and Health Worker Protection Sep-18 Occupational Safety and Health Working Environment Sep-18 Occupational Safety and Health Sep-18 Several electrical panels were missing hazard signs in both buildings. Post the hazard signs on the electrical panels. 6 Ensure that the temperature level is aligned with the recommended 30 C. The factory has installed two new exhaust fans. 87 Temperature exceeded the recommended limit of 30 C. Working Environment Inadequate light levels in sewing, packing, and inspection sections. Ensure that the Lux level is adequate in all sections. The factory has installed new lights bulbs in the sewing lines. 26 Occupational Safety and Health Welfare Facilities Insufficient number of toilets. Ensure to have the appropriate number of toilet based on the workforce. Sep-18 Occupational Safety and Health Welfare Facilities Soap was not available in the men's toilets. Ensure that soap in available in the men's restroom. Sep-18 Occupational Safety and Health Welfare Facilities Eating area that can accommodate only 30 per cent of workers. Ensure that the eating area can accommodate all the workforce. Sep-18 Occupational Safety and Health Health Services and First Aid No health checks provided to workers within the first three months of hiring. Arrange free health checks for workers within the first three months of hiring. 61 Sep-18 Occupational Safety and Health Health Services and First Aid No health checks to workers exposed to work-related hazards. Arrange free health checks to workers exposed to workrelated hazards. 6 Sep-18 Occupational Safety and Health Health Services and First Aid No free annual health checks provided to workers. Arrange free annual health checks for workers. 59 Sep-18 Occupational Safety and Health Health Services and First Aid Insufficient number of medical staff. Hire full medical staff with 8 nurses and 3 doctor's visits per week. 87 Sep-18 Occupational Safety and Health Health Services and First Aid Expired products such as NEOSPORIN found in one first aid box. Remove the expired products from the first aid box. Ensure that they are adequately equipped. Sep-18 Occupational Safety and Health Health Services and First Aid Less than 10 per cent of the workforce trained in first aid. Train an adequate number of the workforce in first aid. 6 Sep-18 Occupational Safety and Health Emergency Preparedness No fire alarm system was observed in the cutting building. Install a fire alarm in the cutting building. 29 87 The management warned the maintenance team to advise whenever soap or paper is missing in the toilets. The factory has enlarged the eating area and provides more benches. The expired product was removed during the assessment. The first aid maintenance is under the responsibility of the nurse who does a check on a 6 87 59 158 Sep-18 Occupational Safety and Health Emergency Preparedness One fire extinguisher obstructed and several unidentified. Fire extinguisher missing in the mechanical workshop and on the mezzanine floor. Less than the 10 per cent of the workforce trained in fire fighting equipment. Install a fire extinguisher near the mechanical workshop. Identify all the fire extinguishers. Sep-18 Occupational Safety and Health Emergency Preparedness Train an adequate number of workers in fire-fighting equipment. 6 Sep-18 Occupational Safety and Health Emergency Preparedness Inaccuracy of the evacuation plan. Post an evacuation plan in the cutting department. Update the evacuation plan displayed in the main building. 47 Sep-18 Occupational Safety and Health Emergency Preparedness One drill performed per year. Conduct one drill every 6 months. 71 Sep-18 Working time Regular Hours Extra breaks not provided to pregnant workers. Provide additional breaks to pregnant women. 6 Sep-18 Working time Regular Hours Several workers worked regularly beyond the time posted on their time cards. Install a reliable attendance system. 15 Sep-18 Working time Regular Hours Factory's working hours not posted in the cutting building. Post factory's working hours inside the workplace. 6 Apr-17 Freedom of Association and Collective Bargaining Interference and Discrimination Termination of union leaders. Reinstate the terminated union leaders. The factory decided to reinstate the union leaders. However, they did not come back to work due to the aggressiveness of other workers. 9 Apr-17 Compensation Wage Information, Use and Deduction Inaccuracy of time record system. Ensure that the payroll records are accurate and reflect the exact working hours. The factory is in the process to buy a punching machine. 9 Apr-17 Compensation Paid Leave Payments for non-working holidays are based on the minimum wage instead of average earnings. Pay leave based on the average earning. 81 Apr-17 Compensation Paid Leave Payments for weekly rest days are based on the minimum wage instead of average earnings. Pay leave based on the average earning. 81 Apr-17 Compensation Paid Leave The payments for sick leave are based on the minimum wage instead of average earnings. Pay leave based on the average earning. The factory has installed a fire extinguisher in the mechanical workshop. 29 Assessment April 2017 After the assessment visit, the factory corrected the sick leave payment and started to pay it based on average earnings. However, since January 2018, the factory refused to pay the sick leave stating that they registered for OFATMA h lth d t it 81 159 Apr-17 Compensation Social Security and Other Benefits The factory calculates ONA contributions based on the minimum wage instead of the base salary and payment is late. Pay ONA on time and forward 6 per cent of workers' base salary for employer's contribution. 9 Apr-17 Compensation Social Security and Other Benefits The factory calculates ONA contributions based on the minimum wage instead of the base salary and payment is late. Pay ONA on time and forward 6 per cent of workers' base salary for worker's contribution. 9 Apr-17 Compensation Social Security and Other Benefits Contribution to OFATMA for work- Pay OFATMA contributions for related accident insurance is based work-related accident on the minimum wage instead of insurance accurately the basic salary. 9 Apr-17 Compensation Social Security and Other Benefits Compensation Social Security and Other Benefits Pay 3 per cent of workers' base salary to OFATMA for maternity and health insurance as employer ib and i forward 3 per cent Collect of worker's base salary to OFATMA for maternity and health insurance as worker's contribution. 9 Apr-17 The factory is paying 2 percent of workers' minimum wage instead of 3 percent of workers' basic salary to OFATMA. The factory is collecting 2 percent of workers' minimum wage instead of 3 percent of workers' basic salary to OFATMA as workers' contribution. Apr-17 Contract and Human Resources Employment Contracts Apprentice workers are compensated less than the salary required by law. Compensate apprentice workers at least 40 per cent of the minimum wage. The factory is in the process to change the apprentice contract accordingly to the legal requirements. 9 Apr-17 Occupational Safety and Health OSH Management Systems No evidence of management conducting assessment of general occupational safety and health issues in the workplace. Regularly assess the OSH points. Elaborate an assessment template. Keep records of assessments performed on a regular basis. The bipartite committee is in charge of performing OSH assessment on a weekly basis and to report the issues to management. 81 Apr-17 Occupational Safety and Health Chemicals and Hazardous Substances Inventory of chemicals used such as thinner were unavailable during the assessment visit. Ensure to get rid of empty chemical containers since the factory does not use chemicals such as thinner in the workplace. 81 Apr-17 Occupational Safety and Health Chemicals and Hazardous Substances Unidentified containers with thinner and oil in the Mechanical Workshop. Ensure to label any container used in the workplace. The factory had an awareness session with his maintenance staff to inform about that thinner is prohibited in the workplace. An inventory of other chemicals bought and used is available Thinner is not used. Management informed the mechanic to label all containers and that chemical such as thinner is forbidden in the factory. Apr-17 Occupational Safety and Health Chemicals and Hazardous Substances No MSDS' were posted for thinner in the Mechanical Workshop. Post MSDS' where workers are using chemicals and dangerous substances. The factory is not using thinner. MSDS is posted for all chemicals used in the mechanical shop 81 9 81 160 Apr-17 Occupational Safety and Health Worker Protection No evidence of training provided to workers to properly use personal protective equipment and machines. Train workers on the use of personal protective equipment. The factory agreed on receiving Occupational Health and Safety training from Better Haiti. Management also agreed to improve the OSH committee. The factory bought finger guard and is in the process to install them where needed. The order was made for the eye guards. 81 Apr-17 Occupational Safety and Health Worker Protection Several sewing machines are missing the necessary guards. Ensure that all sewing machines are properly equipped with the necessary guards. Apr-17 Occupational Safety and Health Worker Protection Electrical distribution boards were not well maintained and electrical outlets were not covered in the Mechanical Workshop. Ensure the electrical maintenance is regularly done. The distribution boards are properly fixed to the wall. 9 Apr-17 Occupational Safety and Health Working Environment Ensure to take appropriate measure to keep the temperature under 30 C. The factory replaced the defective fans and add four more fans throughout the floor. 81 Apr-17 Occupational Safety and Health Working Environment Inadequate light levels in sewing, packing, and inspection sections. Ensure the light levels are appropriate for sewing, packing, and inspection sections. The factory replaced the defective lights. 20 Apr-17 Occupational Safety and Health Welfare Facilities Insufficient number of toilets. Install sufficient number of toilet based on the workforce. Apr-17 Occupational Safety and Health Welfare Facilities Test provided reveals that water is not safe. Provide safe water to workers. Perform new tests that testify that the water is safe. Apr-17 Occupational Safety and Health Welfare Facilities The eating area that can only accommodate 25 percent of its workforce at once. Provide an eating area that can accommodate all the workers Apr-17 Occupational Safety and Health Health Services and First Aid No medical checks were arranged for newly hired workers within the first three months of employment. Arrange a medical check for newly hired workers within the first three months of employment. 55 Apr-17 Occupational Safety and Health Health Services and First Aid Annual medical checks were not arranged for all workers in the last 12 months. Arrange one medical check for all workers. 53 Temperature exceeded the recommended limit of 30 C. 81 81 The factory performed monthly internal tests for the water. They sent new sample to their usual laboratory. The test revealed that the water was safe. The factory has expanded the eating area. The factory is in process to buy benches to arrange the space. 9 81 161 Apr-17 Occupational Safety and Health Health Services and First Aid Insufficient number of medical staff. Comply with the Labor Code regarding the onsite medical staff. Apr-17 Occupational Safety and Health Health Services and First Aid One empty first aid box found on the floor. Ensure that the First Aid Boxes are properly maintained and equipped. Ensure to have a sufficient number of First Aid Boxes within the plant. Apr-17 Occupational Safety and Health Emergency Preparedness No fire alarm system was observed in the second building, which includes the Cutting section. Install a fire alarm system in the second building. Apr-17 Occupational Safety and Health Emergency Preparedness Four unidentified fire extinguishers in the Sewing section. No fire extinguishers found in the stock trim room, the mechanic shop and on the mezzanine floor. Provide fire extinguisher near stock trim room, mechanic shop and the mezzanine floor. Apr-17 Occupational Safety and Health Emergency Preparedness No evacuation plan posted in the second building. Post an evacuation Plan in the second building. Apr-17 Occupational Safety and Health Emergency Preparedness Last fire drill was conducted in July 2015. Conduct two fire drill a year. A drill was conducted in August 2017. 65 Apr-17 Working time Regular Hours Inaccuracy of the attendance records. Ensure that attendance records are accurate and reflect the exact working time. Management said that they are actively looking for an effective punching system. 9 Apr-17 Working time Overtime Excessive overtime. Ensure that overtime hours do not exceed the legal limits. 65 Apr-17 Working time Overtime Prior authorization was not obtained from the Department of Labor before working overtime. Ensure to obtain authorization from the Department of Labor before working overtime. 71 81 The factory bought products for the floor's first aid box. 53 23 The 4 unidentified fire extinguishers are now identified. The ones in the cutting section have been identified also. 23 41 162 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Date of last two Better Work assessments: S&H Global S.A Port-au-Prince 10904 Jun-12 Jun-17 Jun-18 Advisory and Training Services 1-Feb-19 Meeting with 4 trade unions to discuss on OFATMA and factory's updates.Factory tour with OSH committee member. Workers Interviews. 1-Feb-19 Bipartite committee meeting to present a session on successes and failures of 2018. 31-Jan-19 Factory visit to recent work stoppages that occurred in the factory. Discussions with HR managers on difficulties they faced in 2018 and changes for 2019. Review of documentation and improvement plan updates. 8-Nov-18 8-Nov-18 8-Nov-18 7-Nov-18 Factory visit to discuss on the case regarding the termination of a union member. Factory tour to validate the remediation related to OSH. Sexual Harassment Awareness and Prevention training for senior management Workshop to elaborate an action regarding Industrial relation concerns. Factory visit to discuss on the recent strikes and possible steps taken to avoid reoccurrence. Meeting with trade union on the outcome of the two strikes. Revision of the improvement plan and documentation review. 6-Nov-18 25-Oct-18 18-Oct-18 16-Oct-18 Sexual Harassment Awareness and Prevention training for middle management Training of trainers in Sexual Harassment prevention Supervisory Skills training (SST) Training of Trainer supervisory Skills (ToT SST) ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT DETAILS OF NON COMPLIANCE IMPROVEMENT PRIORITIES REMEDIATION EFFORTS MONTHS Assessment June 2018 Jun-18 Occupational Safety and Health Worker Protection Obstructed electrical panel in module one . Exposed wires and electrical installations enclosed in a wooden box. Ensure that electrical installation are adequately safeguarded. Replace the wooden box by an adequate material/cover. All exposed wires were covered and well maintained so that they did not obstruct or cause any danger in the workplace. Furthermore all electrical panels have been unobstructed and enclosed in proper boxes. Jun-18 Occupational Safety and Health Worker Protection No exit signs posted in the maintenance building. Perform regular internal assessment on OSH compliance points. Train the maintenance team on OSH compliance points. Exits signs and emergency lights were installed in the maintenance building. Maintenance received training on OSH compliance point and Better Work provided OSH training on September 2018. 9 163 Jun-18 Occupational Safety and Health Welfare Facilities Paper and soap were not available in the men's bathroom. Provide soap in the men's bathroom. Soap and paper were immediately restocked in the toilets, and this issue was corrected during the assessment. Jun-18 Occupational Safety and Health Health Services and First Aid Factory does not provide health checks for all workers within the first three months of employment. Ensure that newly workers are having their health check done within the first three months. Medical checks for workers have been duly done. The compliance department will thoroughly check all worker's file to confirm they have received the above requirement. Jun-18 Occupational Safety and Health Health Services and First Aid Documented evidence of medical checks were not available in workers files or factory clinic. Facilitate annual medical check for workers before the end of 2018. Ensure that an agenda is set up internally to perform medical check-ups. Properly document internal check ups performed. The factory performed health checks and edited certificates to record each worker 'medical yearly visit. 3 Jun-18 Occupational Safety and Health Gender Factory failed to follow the factory zero tolerance policy relating to Sexual Harassment misconduct. Ensure that all module are respecting the zero tolerance policy. Ensure that all employees working in the HR department and the supervisory lines of each module receive the HR training. Review the zero tolerance policy and consult workers representatives on issues related to Sexual Harassment. Factory carried out an investigation regarding these workers and they were sanctioned. All workers and employers received a full-course Compliance Training regarding Zero Tolerance Policy and Sexual Harassment prevention including middle and top management. 3 Jun-18 Occupational Safety and Health Health Services and First Aid Insufficient number of nurses. Hire a adequate number of medical staff. All the nurses' position have been relocated back again into the factory's medical field. 9 Jun-18 Occupational Safety and Health Health Services and First Aid One expired product found in one first aid box. Remove the expired product. Check regularly the medical supplies. Assign accountability to ensure proper follow up is done. The expired bottle of oxygenated was replaced with a new one. Nurses inside the factories are assigned to check for any missing drugs or expired chemicals that needed replacement weekly. 9 Jun-18 Occupational Safety and Health Health Services and First Aid Less than 10 percent of the workforce trained in first aid. Ensure that 10% of the workforce is train on first aid. Fortify training methods internally. A training was carried out on September 2018. In order to prevent this issue from reoccurring, it is planned to carry out first aid trainings internally every 3 months. 3 3 164 Jun-18 Occupational Safety and Health Emergency Preparedness No smoke detector was installed in the fabric warehouse of one module. Install a smoke detector in the module . Ensure that maintenance is doing on a regular basis for fire-fighting equipment. Smoke detectors have been installed accordingly in the mentioned area. Monthly maintenance are done. 9 Jun-18 Occupational Safety and Health Emergency Preparedness Several fire extinguishers were obstructed and one fire extinguisher found with the pressure gauge broken. Ensure to have adequate procedures in place to monitor the handling of fire extinguisher. Inspect on a regular basis fire extinguishers. Ensure that fire extinguisher remain unobstructed. Ensure that fire extinguisher are properly maintained All fire safety equipment have been unobstructed during the assessment. Additionally, all FCO's and supervisors now have a daily checklist routine with this regard. 24 Jun-18 Compensation Paid Leave Maternity leave payment was paid based on the minimum wage and not based on the average earnings. Review the payment system to ensure the data are accurate. Train the relevant people that are entering the data. The HR Secretary who introduced the digits wrongly was given an in depth training. The compliance department carried out in-depth self audits regarding maternity leave to double check all payments. 18 Jun-18 Contract and Human Resources Dialogue, Discipline and Disputes Incidents of physical and verbal abuse against workers. Ensure that in line supervisor and managers are aware and committed to respect the Zero Tolerance policy in place. Ensure to follow the grievance policy, the HR procedures and dispute resolution policy in place. The washing manager was given both verbal and written warning. A compliance training was carried out for all expat managers. Factory also strengthened our internal auditing system and grievance methodology. 3 Jun-18 Occupational Safety and Health Emergency Preparedness Less than the 10 percent of the workforce in trained in firefighting. Ensure that 10% of the workforce is train in firefighting. Fortify training methods internally. Discuss with top management regarding training schedule. Training was carried out on September 2018. Factory plans to carried out training internally every 3 months. 3 Jun-18 Occupational Safety and Health Emergency Preparedness Evacuation plans were not updated. Ensure that the evacuation maps are updated. All evacuation maps have been updated and posted. 6 Jun-18 Occupational Safety and Health OSH Management Systems OSH Policy has not been developed in consultation with workers and their representatives. Ensure to review the OSH policy in consultation with worker representatives in the bipartite committees. Management reviewed the OSH policy in consultation with workers representative on August 2018. 3 Jun-18 Occupational Safety and Health Chemicals and Hazardous Substances Several chemicals are not included in the inventory. In addition, the inventory does not include all the locations. Ensure that all chemicals used are included in the inventory and that the inventory is adequately documented. The chemical inventory list has been systemized therefore updating the inventory will be effectively done by all departments. 3 165 Jun-18 Occupational Safety and Health Chemicals and Hazardous Substances Unidentified containers of chemicals and hazardous substances. Label all containers of chemicals and hazardous substances. Perform internal audit on a regular basis. Assign accountability for OSH matters. The factory has purchased stickers of that have been attached to all chemical drums and containers. The compliance department will carry out self-audits regarding chemical use and storage each month for every module. 33 Jun-18 Occupational Safety and Health Emergency Preparedness Evacuation routes were obstructed by boxes in the packing area of two modules. Ensure that evacuation routes remain unobstructed; - Assign accountability to monitor such issues. The factory repainted the evacuation routes and additionally, emphasized the supervision of all evacuation routes. Compliance officers and supervisors have a daily checklist routine in this regards. 3 Jun-18 Occupational Safety and Health Emergency Preparedness Fire drills were not conducted every 6 months in all buildings Ensure to perform a fire drill twice a year. Schedule an agenda to perform drill in each module. Document the related evidences. The company has conducted an additional emergency drill that has been monitored by SONAPI. 3 Jun-18 Occupational Safety and Health Working Environment The workplace temperature exceed the recommended 30 C. Maintain temperature level to a maximum of 30 C. Set internal inspections on a regular basis. Management cleaned and inspected all the water cooling systems installed in the factories to lower temperatures. Mechanics checks all cooling systems on a monthly basis.. 9 Jun-18 Occupational Safety and Health Working Environment The noise level exceed the recommended 90 db. in the sewing section, in Module 3. Maintain noise level to a maximum of 90 dB. Set internal inspections on a regular basis. Management has reduced the volume of the music inside the work place and the IT team has set a limit to the music volume in all modules. Workers who work in the pressing section were provided with ear plugs. 33 Jun-18 Occupational Safety and Health Chemicals and Hazardous Substances Chemicals were not stored properly and the storage areas were not adequately ventilated. Store chemical in the appropriate place. Have written procedures on the usage of chemicals. Train chemical users on the handling of chemical. Chemicals were moved to the Chemical room and this issue was immediately corrected during the assessment. 9 Jul-18 Occupational Safety and Health Chemicals and Hazardous Substances MSDS were not available for several products and some were in a foreign language. Ensure that MSDS are available where chemicals are used and stored. Ensure that MSDS are available in the local language. All MSDS have been posted in all chemical using and storing departments. MSDS have been translate into French. 9 166 Jul-18 Occupational Safety and Health Working Environment The level of lighting in the workplace is unacceptable in sewing, cutting and quality sections. Ensure that light levels are adequate in all sections. The factory uses LED light bulbs and all light bulbs were installed again in order to achieve the recommended Lux. Mechanics will check LED light bulbs and lightning equipment monthly. 3 Jul-18 Occupational Safety and Health Chemicals and Hazardous Substances Eye wash stations in the mechanical workshop of one module was not functioning. Ensure that cleaning facility is available in the area where chemical are used. Fix the eye wash station in the mechanical workshop. The factory immediately repaired the defective eye wash. Daily checks are performed to ensure that eye wash stations are always full and operational. 9 Jul-18 Occupational Safety and Health Worker Protection No proper masks were provided to workers in the spot cleaning area. Provide adequate PPE to workers in the spot cleaning areas. Assign accountability to supervisor and factory compliance officer to monitor the availability of PPE. Train spot cleaning area's workers on PPE. The factory provided adequate masks to workers and conducted training for all workers of this section. 33 Jul-18 Occupational Safety and Health Worker Protection Inadequate personal protective equipment in the mechanic workshop of module 5. Provide adequate and necessary PPE to workers. The Compliance department has conducted numerous Trainings related to the use of PPEs to all workers. 33 Jul-18 Occupational Safety and Health Worker Protection Standing workers in module 1 and module 6 were not provided with foot rests or shock absorbing mats. Some chairs provided to the workers were missing back rest. Perform regular OSH audits in each module. Train Factory compliance office on the supply requisition procedures. Ensure that standing workers are provided with foot rests or shock absorbing mats. Standing mats have been stuck onto the floor for standing workers and supervisors have been given the duty of checking if any additional workers need standing mats. New chairs with back rests are provided to workers. 3 Jun-17 Occupational Safety and Health Working Environment Noise levels exceeded recommended levels in pressing. Limit noise levels to a maximum of 90 dB. The factory purchased of a noise level meter to self-check the noise level more frequently. The volume of the music is now reduced in the workplace. Jun-17 Compensation Paid Leave Legally mandated holiday payments for workers entitled to incentives is based on the minimum wage of reference instead of average earnings. Pay legally mandated holiday based on the average earning. Management adjusted the payroll system to calculate the payment for legal holiday based on the average earning. Assessment October 2018 167 Jun-17 Compensation Paid Leave Weekly rest day payments are based on the minimum wage of reference instead of average earnings. Pay weekly rest day based on the average earning. Management adjusted the payroll system to calculate the weekly rest day based on the average earning. Jun-17 Compensation Paid Leave Sick leave payments payment are based on the minimum wage of reference instead of average earnings. Pay sick leave based on the average earning. Management adjusted the payroll system to calculate sick leave based on the average earning. Jun-17 Compensation Paid Leave Maternity leave payment is based on the minimum wage of reference instead of average earnings. Pay maternity leave based on the average earning. Management adjusted the payroll system to calculate maternity leave based on the average earning. Jun-17 Compensation Social Security and Other Benefits Incorrect basis used to calculate the employer's contributions to ONA. Pay 6 per cent of worker's base salary to ONA. Management adjusted the payroll system to collect ONA deduction accurately. Jun-17 Compensation Social Security and Other Benefits The factory has not registered with OFATMA for maternity and health insurance. Employer's contribution is not sent to OFATMA. Register for the maternity and health insurance. Forward employer's contribution to OFATMA. Several meetings were organized with OFATMA to facilitate the implementation of the insurance. Meetings were organized for workers and trade unions to explain the process. Jun-17 Compensation Social Security and Other Benefits The employer does not collect and forward workers contributions to OFATMA. Register for the maternity and health insurance. Collect and forward workers contributions to OFATMA. Several meetings were organized with OFATMA to facilitate the implementation of the insurance. Meetings were organized for workers and trade unions to explain the process. Jun-17 Contract and Human Resources Employment Contracts Workers wrongfully categorized as workers doing temporary work. Review the employment status for all the concerned workers and issue adequate contracts. The factory changed the contracts of temporary & contracted workers to regular workers. All the relevant workers had signed on a new regular contract with corresponding benefits. Jun-17 Working time Overtime No authorization from the Department of Labor before working overtime. Ensure to have MAST approval prior working overtime. HR department managed to receive all the MAST approvals for the overtime hours. 168 Jun-17 Contract and Human Resources Contracting Procedures Overtime hours exceeded the legal limits. Ensure that legal limit of overtime is respected. The factory revised its internal procedures to ensure in order to control the OT hours. All the modules and department do not work Overtime on Monday and Saturday. Jun-17 Occupational Safety and Health OSH Management Systems Work-related accidents and diseases records were not submitted to OFATMA on a monthly basis. Send on a monthly basis the accident records to OFATMA. Ensure to have a stamped receipt. The factory received the Certificates from OFATMA. Jun-17 Occupational Safety and Health Chemicals and Hazardous Substances Several unidentified containers of chemicals and hazardous substances found in the workplace. Chemical products and chemical storages should be controlled properly. Assign a person in charge of monitoring the chemical labelling. Management completed marking on the water tanks and all the other types of tanks such as oil tank, gas tank .The mechanics and the factory compliance officers are in charge. Jun-17 Occupational Safety and Health Chemicals and Hazardous Substances No MSDS' were posted for chemicals used in the spare mechanical parts warehouse in Module 1. Ensure that MSDS are available where chemicals are used and stored. Ensure that MSDS are available in the local language. All MSDS are posted. The main office compliance team is conducting regular weekly audits to ensure that MSDS are always available. Jun-17 Occupational Safety and Health Chemicals and Hazardous Substances The eye wash station in the maintenance room near warehouse 2 was not working. Perform regular checks to ensure all washing facilities are functioning. During the assessment the defective eye wash station was repaired and factory compliance officers are performing daily checks on the washing facilities. Jun-17 Occupational Safety and Health Worker Protection The majority of the workers in the pressing section were not using the protective ear plugs provided by the factory. Train workers and supervisors on the usage of the protective equipment. PPE are provided to workers. The employer has trained the workers in the use of PPEs and has issued warning letter, when required. Jun-17 Occupational Safety and Health Worker Protection Single needle machines were found missing finger guards in building 1. Repair all missing finger guards. Conduct regular inspection of finger guards on all machines. This issue have been immediately treated by installing the finger guards . Jun-17 Occupational Safety and Health Worker Protection No exit sign was posted in warehouse 2. Ensure that all exits are identified. Management took immediate corrective action during the assessment. Jun-17 Occupational Safety and Health Welfare Facilities Insufficient number of toilets. Provide more restrooms for men. Jun-17 Occupational Safety and Health Health Services and First Aid Insufficient number of nurses. Recruit More nurses. The factory switched a number of female toilets to men's toilets. Now they have 183 men's toilets and 432 women's toilets. The factory hired 4 additional permanent nurses. 169 Jun-17 Occupational Safety and Health Health Services and First Aid One additional first aid box installed in the main storage area. Ensure that first aid boxes are easily accessible. Additional First Aid Box has been installed in the main storage area. Jun-17 Occupational Safety and Health Emergency Preparedness Access to one of the installed fire alarm switches in the maintenance room was obstructed. No smoke detectors were installed in warehouses 1 and 2. Ensure that fire fighting equipment remain available. Install smoke detectors in warehouse 1 and 2. During the assessment, management clear the fire alarm area. Smoke detectors are installed at Warehouse 1 & 2. Jun-17 Occupational Safety and Health Emergency Preparedness Unreliable fire extinguisher maintenance services. Ensure that the maintenance of the fire extinguisher are made by experts. Maintain regular check on the fire extinguishers. All the fire extinguishers are placed at their proper position. Jun-17 Occupational Safety and Health Emergency Preparedness Evacuation plans in all buildings were missing in the washing laboratory. Ensure to post an evacuation map in the washing laboratory. Evacuation map is now posted in all the factories/departments. Jun-17 Working time Regular Hours Multiple work schedules inconsistent with collective working agreements and the law. Ensure to have for any work hour changes. Respect national law and conventions when changing the working time. Company sent an approval letter from MAST. All workers are informed of the new working hours. Jun-17 Working time Overtime The overtime hours exceeded the legal limit. Control overtime hours. The factory revised its internal procedures to ensure in order to control the OT hours. Company has internally limited the OT hour from 80 hours to 72 hours per 3 months. Jun-17 Occupational Safety and Health OSH Management Systems Factory did not submit the workrelated accidents and diseases records to OFATMA on a monthly basis. Submit accidents records to OFATMA on a monthly basis. The factory submitted all accidents records to OFATMA. The compliance department is in charge of ensuring that this is done on a monthly basis. 170 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Date of last two Better Work assessments: Silver Linings S.A Port-au-Prince 611 Oct-09 May-18 Jun-17 Advisory and Training Services Advisory visit to conduct a quick assessment of social dialogue, grievance handling mechanism, and learning plan. Follow up on the risk assessment action plan. 14-Mar-19 Review employer contribution to social security. OSH factory tour. 13-Mar-19 Meeting to discuss about the location of the cafeteria and information sessions that will be provided by the compliance team. Furthermore, discuss the training needs. 18-Jan-19 Meeting to discuss about the role of the committee for this year. Also, how the members will respect their commitments. 7-Dec-18 Workshop on Gender challenges at the workplace. 30-Nov-18 Factory visit to verify medical checks for workers. Verify the records of accidents submitted to OFATMA. Review the OSH self assessment. Review the Accident investigation report. OSH Factory tour. 30-Nov-18 Training in Sexual Harassment in the events of Share Hope 30-Nov-18 Training in Sexual Harassment Awareness and Prevention Workers 30-Nov-18 Meeting to present the grievance and OSH policy. 27-Nov-18 Training in Sexual Harassment in the events of Share Hope ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT DETAILS OF NON COMPLIANCE IMPROVEMENT PRIORITIES REMEDIATION EFFORT MONTHS Assessment May 2018 May-18 Compensation Social Security and Other Benefits Employer contribution to ONA is less than 6 percent of workers' base salaries. Ensure that ONA payment is based on the base salary instead of worker's minimum wages. Submit the monthly payment within the first 10 working days of the following month. 24 May-18 Compensation Social Security and Other Benefits Workers' contributions to ONA is base on the minimum wage. Ensure that ONA payment is based on the base salary instead of worker's minimum wages. 24 May-18 Compensation Social Security and Other Benefits Payment of employer's contribution to OFATMA for the maternity and health insurance is inaccurate. Forward 3 percent of workers' base salary to OFATMA for maternity and health insurance. 24 171 May-18 Compensation Social Security and Other Benefits Payment of workers' contribution to OFATMA for the maternity and health insurance is inaccurate. Collect and forward 3 percent of workers' base salary to OFATMA for maternity and health insurance. 24 May-18 Occupational Safety and Health Chemicals and Hazardous Substances Unlabelled containers of machine oil in the generators' room. Label all hazardous and chemicals substances used in the workplace. All containers have been identified. The compliance officer is assigned to conduct the daily and weekly checks. 10 May-18 Occupational Safety and Health Emergency Preparedness The routes in the storage and warehouse areas are not clearly marked. Paint evacuation arrows and signs All markings and painting has been done on the floor and all exits and signs have been identified. 10 May-18 Occupational Safety and Health Health Services and First Aid The factory does not provide workers health checks within the first three months of hiring. Provide workers health checks within the first three months of hiring. Medical exams have already started. A schedule has been created to identify who and when exams will be conducted. 10 May-18 Occupational Safety and Health Health Services and First Aid The factory did not show evidence of annual medical checks for workers. Provide annual medical checks for workers. Medical exams have already started. A schedule has been created to identify who and when exams will be conducted. 10 May-18 Occupational Safety and Health Health Services and First Aid Onsite medical facilities and staff is insufficient. Hire the additional medical staff. The factory hired an additional nurse to comply with the current workforce. 10 May-18 Occupational Safety and Health OSH Management Systems Legally required construction/building permits Perform a building safety inspection. May-18 Occupational Safety and Health OSH Management Systems The OSH policy is not signed by top management and it was not developed in consultation with worker representatives. Translate the OSH policy into the local language, consult with worker representatives an ensure that the policy is signed by top management. 10 OSH policy is signed and presented to the bipartite committee. 10 172 May-18 Occupational Safety and Health Welfare Facilities The results of water test revealed the presence of colonies after 48 hours Provide free drinking water to workers The maintenance manager has been assigned to manage the water filtration system. 10 May-18 Occupational Safety and Health Worker Protection Standing workers in the stock room operating without standing mats. Provide standing mats to the standing workers All floor mats have been installed to all required sections . In addition, the dailyweekly checks have been updated. 10 The factory calculates and pays legal mandated holidays based on minimum wage and number of days present according to 6 days of work per week. Assessment June 2017 Jun-17 Compensation Paid Leave Payment for legally mandated holidays are based on the minimum wage instead of workers' average earning. Adjust payroll system to ensure that payment for legally mandated holidays are accurate. Jun-17 Compensation Paid Leave Payment for weekly rest days is based on the minimum wage instead of workers' average earning. Adjust payroll system to ensure that payment for weekly rest days is accurate. Jun-17 Compensation Paid Leave Payments for sick leave are based on the minimum wage instead of workers' average earning. Adjust payroll system to ensure that payment for weekly rest days is accurate. Management has made changes in the payroll. Payments for sick leave are based on workers' average earning. Jun-17 Compensation Paid Leave Payments for maternity leave are based on the minimum wage instead of workers' average earning. Adjust payroll system to ensure that payments for maternity leave are accurate. Payments for maternity leave are based on workers' average earning. Jun-17 Compensation Social Security and Other Benefits Employer Contribution to ONA Ensure that ONA payment is based on the basic salary instead of worker's average earnings. Jun-17 Compensation Social Security and Other Benefits Collecting and forwarding workers contributions to ONA. Ensure that ONA payment is based on the basic salary instead of worker's average earnings. 173 Jun-17 Compensation Social Security and Other Benefits Employer contributions to OFATMA for work related accident insurance are based on the minimum wage. Ensure that contributions to OFATMA for work related accident insurance are based on the general wage. Jun-17 Compensation Social Security and Other Benefits Employer contribution to OFATMA for maternity and health insurance. Collect and forward 3 per cent of worker's average earnings. Jun-17 Compensation Social Security and Other Benefits Collect and forward worker's contribution to OFATMA for maternity and health insurance. Ensure that 3 per cent of worker's average earnings are collected and forwarded to OFATMA for maternity and health insurance. Jun-17 Occupational Safety and Health Worker Protection About 60 percent of single needle machines were missing finger guards. No pulley guards on Union Special machines and 3 bar tack machines were missing eye guards. conduct a monthly inventory of guards installing on machines. Ensure that proper guards are installed on all machines. All the guards have been installed and the mechanical department is responsible of the weekly inventory. Jun-17 Occupational Safety and Health Emergency Preparedness The factory's basement, which served as a fabric warehouse, did not have Fire detection and alarm system. Install a fire detection and alarm system. Fire detection has been installed. Jun-17 Occupational Safety and Health Emergency Preparedness The factory's basement, which served as a fabric warehouse, did not have any fire-fighting equipment. Install fire-fighting equipment in the basement, designate a person in charge of the monthly audit. Fire fighting equipment has been installed in the basement. Jun-17 Occupational Safety and Health Chemicals and Hazardous Substances Workers in the spot cleaning area were not using the protective masks adequately. Provide additional training to workers in the spot cleaning on the use of PPE. Training on PPE has been done and workers are using adequately the protective mask. 174 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Date of last two Better Work assessments: Sewing International S.A Port-au-Prince 1885 Sep-09 Jun-18 May-17 Advisory and Training Services 3-Mar-19 Bipartite committee to discuss members identification on the floor and review the improvement plan. 1-Mar-19 Factory visit to Discuss factory bipartite committee functioning and Improvement Plan with Compliance officer 29-Jan-19 7-Dec-18 14-Nov-18 13-Nov-18 26-Oct-18 Training in Respectful Workplace Program with Electra Sewing Workshop on women challenges in the workplace. Building Bridges Workshop Factory visit to verify OSH compliance remediation's and FOA policy with HR and Plant managers. Bipartite committee to discuss various prevention measures to reduce non compliance at the factory. ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT DETAILS OF NON COMPLIANCE IMPROVEMENT PRIORITIES REMEDIATION EFFORTS Overtime hours have been clarified with workers, hours are posted. MONTHS Assessment June 2018 Jun-18 Compensation Overtime Wages Insufficient transparency of overtime hours recorded and compensated by the factory. Clarify limit of overtime hours and the formula for payments in factory internal working rules. Inform workers of their right to refuse overtime. 10 Jun-18 Compensation Wage Information, Use and Deduction Wage deductions, such as loan, made by the employer exceeding 1/6 of workers monthly earnings. Ensure that wage deductions, such as loan, made by the employer do not exceeded 1/6 of workers' monthly earnings. 10 Jun-18 Compensation Wage Information, Use and Deduction Time records of overtime hours worked without authorization are not recorded in the payroll and are not compensated. Clarify limit of overtime hours and the formula for payments in factory internal working rules. Ensure that time records of all overtime hours worked are recorded in the payroll and compensated. 10 175 Jun-18 Compensation Social Security and Other Benefits Payments for ONA are based on the minimum wage instead of worker's basic salary as required by the Haitian Labour Code. Worker's contributions to ONA are based on the minimum wage instead of the worker's basic salary as required by the Haitian Labour Code. Ensure employer contributions for ONA are 6% of the worker's basic salary as required by the Haitian Labour Code. Ensure worker contributions for ONA are 6% of the worker's basic salary as required by the Haitian Labour Code. 36 Jun-18 Compensation Social Security and Other Benefits Jun-18 Compensation Social Security and Other Benefits Agreement to pay work-related accident insurance in four monthly instalments not current. Follow instalment agreements approved by OFATMA and make payments according to expected deadlines 10 Jun-18 Compensation Social Security and Other Benefits The employer's contribution to OFATMA for maternity and health insurance is 2% of the minimum salary for 20 days worked instead of 3% of workers' base salary as required by law. Ensure the employer's contribution to OFATMA for maternity and health insurance is based on 3% of workers' base salary as required by law. 36 Jun-18 Compensation Social Security and Other Benefits The factory is collecting 2% of minimum salary for 20 days worked instead of collecting 3% of workers' base salary as required by law. Ensure the employer's contribution to OFATMA for maternity and health insurance is based on 3% of workers' base salary as required by law. 36 Jun-18 Contract and Human Resources Termination Number of days actually worked in the calculation of indemnity for the notice period considers holidays and weekly rest days which lowers the daily average earning. Compute average earnings based on days actually worked not including holydays and weekly rest days. 10 Jun-18 Contract and Human Resources Termination Annual supplement or bonus amount upon termination found in payroll records is not matching correct amount calculated by the accounting information systems. Verify that payroll system is programmed to respect correct formula and pay correct amount for termination bonus 10 36 176 Jun-18 Contract and Human Resources Dialogue, Discipline and Disputes Procedures for worker terminations were not properly followed. 1. Ensure application of the legal requirements related to termination of contracts under the article 42 of the labour code. 2. Follow MAST recommendation with the reinstatement of the five union leaders Officers accepted termination settlements over reinstatement. 10 Jun-18 Occupational Safety and Health OSH Management Systems OSH policy was not developed in consultation with workers and their representatives and was not signed by top management Enter consultation with workers and their representatives on existing OSH policy for possible input and/or modification. Ensure that it is signed by top management. 10 Jun-18 Occupational Safety and Health Chemicals and Hazardous Substances Factory chemical inventory is incomplete. Ensure that all chemicals currently in use are tracked and included in the daily inventory. 10 Jun-18 Occupational Safety and Health Chemicals and Hazardous Substances Missing MSDS in the chemical room for some chemicals. 10 Jun-18 Occupational Safety and Health Chemicals and Hazardous Substances Management does not isolate the use of chemicals such as Blow Out in the spot cleaning areas and inspection sections. Obtain and post the MSDS in local language for all chemicals stored or eliminate use in production. Management to control and oversee workers' exposure to chemicals and hazardous substances. Ensure isolation of such chemicals. Jun-18 Occupational Safety and Health Chemicals and Hazardous Substances Inspection worker performing tasks assigned to spot cleaning without supervisor approval in her section where eye wash station was not available. Train workers on proper health and safety procedures Workers were trained accordingly 10 Jun-18 Occupational Safety and Health Worker Protection Management did not provide personal protective equipment such as helmet, face shield, safety glasses, gloves, aprons for workers in the welding workshop. Provide helmet, face shield, safety glasses, gloves, aprons for workers in the welding workshop All appropriate personal protective equipment were provided. 10 Jun-18 Occupational Safety and Health Worker Protection 1. Chairs without backrest in use by workers on floors. Ensure workers are provided with chairs with proper backrest 10 Jun-18 Occupational Safety and Health Worker Protection 25% of all sewing machines were missing pulley guards. 90 % of tape machines were missing belt guards. Install all the required safety guards on all sewing machines. 10 10 177 Jun-18 Occupational Safety and Health Worker Protection 2 uncovered electrical boxes with exposed electrical wires in the compressor room. Workplace temperatures in the sewing, quality and pressing sections exceeded BW recommendation of 30 C. Ensure electrical boxes are properly covered with no combustible materials. Use electrical exhaust fans or cooling system. Ensure that the air-flow to and from the fans is not blocked. Make sure that all fans are well-maintained and regularly cleaned. Jun-18 Occupational Safety and Health Working Environment Jun-18 Occupational Safety and Health Jun-18 10 Working Environment Insufficient level of lighting in some sections. Specify who is in charge of regular maintenance of the light and replace defective ones. Conduct regular measurement & compare with BW recommended limit. 10 Occupational Safety and Health Welfare Facilities Insufficient number of toilets available for men and women. Increase the number of toilets. 54 Jun-18 Occupational Safety and Health OSH Management Systems Dust accumulates on the surfaces of electrical equipment and machines. Combustible materials like fabric waste, plastic or paper are scattered around the workplace. Provide more efficient cleaning equipment to assigned personnel for hygienic maintenance of factory floor. 10 Jun-18 Occupational Safety and Health Welfare Facilities The eating area can only accommodate about 25 percent of the workers. Consider expansion of eating area or adoption of different lunch breaks as production can allow to accommodate available eating space. 90 Jun-18 Occupational Safety and Health Health Services and First Aid At the time of assessment, factory did not deliver annual medical health checks to all workers. Develop more aggressive schedule of medical checks for all the workers and ensure completion by next annual evaluation. 90 Jun-18 Occupational Safety and Health Health Services and First Aid Insufficient medical personnel Have a permanent onsite medical service, with at least 10 nurses and 3 doctor's visits per week 90 Jun-18 Occupational Safety and Health Emergency Preparedness Locations of escape routes, emergency exit doors, assembly areas, fire extinguishers, the routes in the packing area are not clearly indicated on the evacuation plan Update evacuation plan to include all required elements Jun-18 Working Time Overtime Workers had worked more than 80 hours of overtime during that trimester. Reduce the number of overtime hours. 66 Evacuations plans are current with all required elements. 10 90 178 Assessment April 2018 May-17 Compensation Paid Leave Payment for maternity leave is based on the minimum wage instead of the workers' average daily earnings. Adjust payroll system to ensure that maternity leave payment is accurate. Maternity payments are now based on average earnings. May-17 Compensation Paid Leave Payment for sick leave is based on the minimum wage instead of the workers' average daily earnings. Adjust payroll system to ensure that sick leave payment is based on workers' average daily earnings. Sick leave are now based on average earnings. May-17 Compensation Social Security and Other Benefits Employer contribution to OFATMA for maternity and health insurance. Collect and forward 3 per cent of worker's basic salary May-17 Compensation Social Security and Other Benefits Collect and forward worker's contribution to OFATMA for maternity and health insurance. Ensure that 3 per cent of worker's basic salary are collected and forwarded to OFATMA for maternity and health insurance. May-17 Working Time Overtime Workers from packing, extra and utility worked up to 137 hours of overtime per trimester. Monitor overtime hours worked in order to comply with the 80 hours allowed per trimester. No action needed. 3/8 law of September 2017 abolish this requirement. May-17 Working Time Overtime Request authorization to work overtime from MAST Request an authorization for overtime hours. No action needed. 3/8 law of September 2017 abolish this requirement. May-17 Occupational Safety and Health Health Services and First Aid The factory only has 2 nurses and 3 doctor's visits per week. Increase the number of nurses to comply with the legal requirements. May-17 Occupational Safety and Health Health Services and First Aid Medical Check for workers upon hiring. Workers received medical checks within first 3 months. May-17 Occupational Safety and Health Health Services and First Aid Annual medical checks for workers. Ensure that workers received medical checks within their first three months of hiring. Ensure Annual medical checks is provided to all workers. May-17 Occupational Safety and Health Health Services and First Aid Health checks for workers who are exposed to work related hazards. Provide medical checks at least twice a year to workers who have been exposed to work related hazard. Workers exposed to chemicals receive medical checks twice yearly. 179 May-17 Occupational Safety and Health Chemicals and Hazardous Substances Labelling of chemicals and hazardous substances in spot cleaning area. Label all containers and provide instructions to supervisors on labelling chemicals substances. Monitor the labelling of containers All containers are appropriately labelled and monitored. May-17 Compensation Social Security and Other Benefits The employer's contribution to ONA is based on the minimum wage. The employer should pay 6 percent of the workers basic salary to ONA. Ensure on time and accurate payments to ONA. May-17 Compensation Social Security and Other Benefits The workers' contribution to ONA is based on the minimum wage. According to the labour code workers should contribute 6 percent of their basic salary to ONA. Ensure on time and accurate payments to ONA. May-17 Occupational Safety and Health Emergency Preparedness Fire fighting equipment not installed in the trim warehouse on floor 8. Install smoke detectors in the trim warehouse 2. Identify areas that need additional smoke detectors 3. designate a person in charge of the monthly audit Smoked detector was installed in the trim warehouse. May-17 Occupational Safety and Health Emergency Preparedness Emergency exit obstructed with fabric. Designate OSH committee focal points in collaboration with floor supervisors to ensure that all the exits remain unblocked. Committee focal points perform routine checks accordingly. May-17 Occupational Safety and Health Working Environment Workplace temperatures in the sewing, quality and pressing sections exceeded BW recommendation of 30 C. Use electrical exhaust fans or cooling system. Ensure that the air-flow to and from the fans is not blocked. Make sure that all fans are well-maintained and regularly cleaned. May-17 Occupational Safety and Health Welfare Facilities Insufficient number of toilets available for men and women. Ensure that number of toilets is compliant with the legal requirements. May-17 Occupational Safety and Health Welfare Facilities Hand washing facilities and lack of adequate soap. Ensure that soap is available at all times in the toilets. May-17 Occupational Safety and Health Welfare Facilities Eating area insufficient for the total number of workers in the factory. Increase the capacity of the eating area. Availability of soap was verified 180 May-17 Freedom of Association and Collective Bargaining Interference and Discrimination Termination procedures of union officers for allegedly disturbing production during strike. Reinstate the 5 terminated union officers with compensation for back pay, in line with the recommendation of reinstatement made by MAST. Union officers accepted termination settlements over reinstatement. May-17 Freedom of Association and Collective Bargaining Freedom to Associate Allegations of Termination of at least 25 union members due to reduced business and/or their union activities. Give priority in rehiring to the workers who were terminated during June, July and August due to reduced business in the event that additional workers with comparable qualifications are required. Union officers accepted termination settlements over reinstatement. 181 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Date of last two Better Work assessments: Interamerican Woven S.A. Port-au-Prince 879 Oct-09 Aug-17 Nov-18 Advisory and Training Services Factory visit to discuss on Improvement plan and general updates. Review of documentation and specifically management system document to make specific recommendation. Factory OSH tour to validate the remediation. 21-Mar-19 Factory visit to discuss on factory updates. Discussion was also on the improvement plan. Review of documentation and factory tour to validate remediation. Discussion on the strategy to re-implement the PICC meeting. 26-Feb-19 Discussion was also on the new training plan for 2019. 31-Jan-19 13-Dec-18 8-Dec-18 8-Dec-18 8-Dec-18 8-Dec-18 7-Dec-18 4-Dec-18 1-Dec-18 28-Nov-18 27-Nov-18 12-Nov-18 Respectful workplace program Risk Management & Control Factory visit to discuss on the Improvement plan and on the Portal issues raised by management . Setting a plan to re-implementation the PICC committee in the beginning of 2019. Sexual Harassment Awareness and Prevention Middle Management Sexual Harassment Awareness and Prevention Workers Sexual Harassment Awareness and Prevention Supervisors Workshop on the challenges of women in the workplace Training of Trainer supervisory Skills (Tot SST) Chemical Management System Factory visit to discuss on the Improvement plan. Review of the evidences submitted and factory tour to validate the remediation. Setting of training dates to complete the 25 training days. Sexual Harassment in the events of Share Hope factory visit to discuss on remediation made for the Cycle 12. Review of the Progress report 2.Document review to validate all the changes made. Factory Tour to validate Osh remediation. ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT DETAILS OF NON COMPLIANCE IMPROVEMENT PRIORITIES REMEDIATION EFFORTS MONTHS Nov-18 Discrimination Interference and Discrimination Termination of union leaders for invalid reasons. Reinstatement of this union leader, with compensation for back pay. Nov-18 Compensation Overtime Wages Not all overtime hours are paid. Pay overtime hours to workers who worked overtime. Inform workers that workers spent on bathroom after 4pm will not be compensated. Workers have been informed that time spent between 4:00 and 4:25 PM using restrooms will not be compensated. Evidence was provided that workers are informed and accurately paid for all overtime hours worked. 22 Nov-18 Compensation Paid Leave Workers eligible for maternity leave only receive 6 weeks as the factory is not registered in OFATMA for maternity and health insurance. Register in OFTAMA health and maternity insurance. IW is launching the process of registering its workers to OFATMA maternity and Health insurance. Management hope to complete it before the end of the year. 55 Assessment November 2018 18 182 Nov-18 Compensation Social Security and Other Benefits ONA contributions are late and based on a fixed salary for all workers. Pay 6 percent of the worker's basic salary to ONA for the employer contribution. Ensure the payment is on time as prescribed by the law. The factory has adapted its method of paying ONA, starting October 1st 2018, to reflect exactly the presence of the workers instead of the 5-day week method which was adopted in an effort not to penalize the workers. 55 Nov-18 Compensation Social Security and Other Benefits ONA contributions are late based on a fixed salary for all workers. Pay 6 percent of the worker's basic salary to ONA for worker contribution. Ensure the payment is on time as prescribed by the law. The factory is now paying ONA on a monthly basis, for workers' contribution, 6% of their basic salary, excluding their overtime pay, as stipulated in the Haitian labour code. 55 Nov-18 Compensation Social Security and Other Benefits The amount paid by the employer to OFATMA is less than 3 percent of the workers' base salary for the work related accident insurance.. Adjust the OFATMA payment for work related accident to 3% f the workers 'base salary. Nov-18 Compensation Social Security and Other Benefits The factory has not registered with OFATMA for maternity and health insurance. Register with OFATMA for maternity and health insurance. The factory has forwarded all requested document to OFATMA for the workers 'registration. 55 Nov-18 Compensation Social Security and Other Benefits The factory has not registered with OFATMA for maternity and health insurance. Collect and forward the deductions to OFATMA for maternity and health insurance. The factory has forwarded all requested document to OFATMA for the workers 'registration. 55 Nov-18 Contract and Human Resources Employment Contracts The internal rules are less favourable than the worker's contracts regarding working time. Pay the overtime worked. All overtime hours are properly reported and workers are duly paid for all overtime hours worked. 5 Nov-18 Contract and Human Resources Contracting Procedures Welding workers not provided with insulated gloves, boots, goggles and ear plug. Provide PPE to workers when necessary. 5 Nov-18 Occupational Safety and Health OSH Management Systems OSH policy has not been developed in consultation with workers representatives. Update the OSH policy in consultation with workers and their representatives. The factory provides PPE to workers when necessary. Workers has to sign an awareness form to acknowledge the receipt of the equipment. IW's written OSH policy has been revised and signed by management and all members of OSH committee. 55 5 183 Nov-18 Occupational Safety and Health Chemicals and Hazardous Substances Incomplete inventory of chemicals and hazardous substances used in the workplace. Assign clear responsibility to OSH compliance manager Train OSH committee on chemical handling. Former OSH officer has been replaced and newly hired OSH officer will be properly trained to accurately perform all OSHrelated duties. Training on chemical handling was completed. 18 Nov-18 Occupational Safety and Health Chemicals and Hazardous Substances Several unidentified containers of chemicals. Identify all containers used in the workplace. Assign clear responsibility for the labelling of the chemical and hazardous substances. All container used are identified and labelled. 37 Nov-18 Occupational Safety and Health Chemicals and Hazardous Substances Chemicals were not properly stored. Ensure that chemical is properly stored. Chemical are kept in an umbrageous area and an adequate cabinet is available to store all chemicals . 18 Nov-18 Occupational Safety and Health Chemicals and Hazardous Substances MSDS was not available for spot remover, WD 40, Aero brand inks, Mist spray 200 and Spray Adhesive. Ensure that MSDS are available for all chemical used in the workplace. MSDS are available for all chemical used in the workplace. 37 Nov-18 Occupational Safety and Health Chemicals and Hazardous Substances Eye wash station in the spot cleaning was not operational. Eyewash station in spot cleaning of Building 29 has been repaired. 37 Nov-18 Occupational Safety and Health Worker Protection Management did not provide ear plug for workers in the press section where the music was recorded to be at 94dB. Ensure that washing facilities are available near area where chemical and hazardous substances are used. Provide earplugs to workers in the press section Earplugs are provided to workers in the press section. 5 Nov-18 Occupational Safety and Health Worker Protection No evidence of training on safe usage of machines. Train workers on the importance of the guards installed on their machines. Factory has conducted training on the importance of machine guards and workers have been informed of measures in place to reinforce discipline. Factory also has on ongoing training plan over the year. 18 Nov-18 Occupational Safety and Health Worker Protection Some standing workers were not provided with foot rests or shock absorbing mats and several chairs missing backrest. Ensure that all the chairs provided to workers are equipped with back rest. Nov-18 Occupational Safety and Health Worker Protection More than 30 percent of all machines in Building 30 were missing pulley guards. Ensure that all the sewing machines are equipped with required safety guards. 5 IW has a system in place. The factory is doing training on the more regular basis on the importance of the guards and will take measures to reinforce discipline. 55 184 Nov-18 Occupational Safety and Health Worker Protection One uncovered electrical boxes with exposed wires in the compressor room. Ensure that the electrical system is properly maintained and safeguarded. The electrical system is properly maintained on a weekly basis. The wire of the pressing machine were properly covered within the week of the assessment visit. 40 Nov-18 Occupational Safety and Health Worker Protection Several electrical panels were missing hazard signs. Post hazard signs on the electrical panels. Management has already ordered everything to set up building to be compliant. Hazard signs have been posted on all electrical panels of building. 18 Nov-18 Occupational Safety and Health Working Environment Temperature level exceeded the recommended 30 C. Monitor the temperature level to a maximum of 30 C. Additional fans have been installed throughout facility and temperatures are being monitored by an application. 37 Nov-18 Occupational Safety and Health Working Environment The noise level exceeded 90dB in the pressing section. Ensure that the noise level comply with Better Work recommendation. This was corrected the same day of the audit, as it was caused by a speaker next to the pressing area of Building 30 that was louder than acceptable db. Now all is within acceptable levels. 5 Nov-18 Occupational Safety and Health Working Environment The light levels were inadequate in the sewing and packing sections. Ensure that the light level is acceptable and comply to Better Work recommendation. Factory has complied to this requirement. Bulbs with higher levels of luminosity have been installed in all sections mentioned above and levels have been monitored and kept in compliance. 18 Nov-18 Occupational Safety and Health Welfare Facilities Insufficient number of toilets. Ensure that the factory is compliant with the number of toilets in regard with the workforce. SONAPI has already come to factory for assessment and will start building new bathrooms at the end of the month (November 2018). 91 Nov-18 Occupational Safety and Health Welfare Facilities Soap was not available in the men's toilets. Ensure soap is available for the use of the workers. At time of assessment, a bar of soap was available in the men's bathroom of building 10, however the liquid soap dispenser was broken. Management added new soap dispensers and replaced the broken one. 5 Nov-18 Occupational Safety and Health Welfare Facilities Eating area cannot accommodate all the workforce at once. Ensure that the eating area can accommodate all the worker. SONAPI does provide and administer a general cafeteria facility that several workers chose not to use. 91 185 Nov-18 Occupational Safety and Health Health Services and First Aid Factory did not provide workers health checks within the first three months of hiring. Ensure that workers receive the health checks within the first 3 month of hiring. Management provided proof that 70 per cent of workers within the first 3 months of hiring were already done with health checks. 5 Nov-18 Occupational Safety and Health Health Services and First Aid Factory did not provide workers health checks to workers exposed to work-related hazards. Ensure that workers exposed to work-related hazards receive at least 2 health checks throughout the year. Factory completed all health checks for workers using hazardous materials or substances. 5 Nov-18 Occupational Safety and Health Health Services and First Aid Factory does not provide workers health checks to workers with free annual health checks. Ensure that workers receive a free annual medical check. 5 Nov-18 Occupational Safety and Health Health Services and First Aid insufficient number of medical staff. Have a compliant number of nurse regarding the workforce. The factory decided to pay globally the yearly cost of the Health Cards and let OFATMA handle the work flow at its pace Factory employs 3 full-time nurses, 1 doctor present 3 times a week and on-call the rest of the week, and one supervisory doctor who visits frequently. With the current workforce, it represent a sufficient medical staff. Nov-18 Occupational Safety and Health Health Services and First Aid Expired products found in one First Aid box. Ensure to check the first aid box in a regular basis. The expired product was removed from the first aid box. A regular check is performed on a weekly basis to control the first aid box. 37 Nov-18 Occupational Safety and Health Emergency Preparedness No fire alarm system in building 5. Install a fire alarm in building 5. Fire alarm has been completely installed in building 5 and is fully functioning. 18 Nov-18 Occupational Safety and Health Emergency Preparedness Several fire extinguishers were missing and some fire extinguishers were not identified and missing the inspection tag in building 5. Identify all available fire extinguishers. All fire extinguisher are identified and regularly maintained. 37 Nov-18 Occupational Safety and Health Emergency Preparedness No evacuation plan is available in building 10 and 5. Post the evacuation plan in buildings 5 and 10. Update the evacuation plan to reflect the reality of the workplace. Evacuation plans have been implemented and posted in both buildings 10 and 5. 5 Nov-18 Occupational Safety and Health Emergency Preparedness One emergency exit locked during working hours. The exit was unlocked during the assessment visit. 5 Nov-18 Occupational Safety and Health Emergency Preparedness One fire drill was conducted within a year. Ensure that emergency exit remained unlocked during the working time. Ensure that an emergency drill occurs every 6 months. Emergency fire drill scheduled for the 27 of November 2018. It will also ensure that drills occur every six months. 5 Assessment May 2017 37 186 May-17 Occupational Safety and Health Worker Protection Several workers in the sewing area, washing room and spot cleaning area were not using the protective devices attached to their machines or the PPE provided to them. Provide training to ensure that workers are aware of safe working practices and follow them accordingly. Maintain records of all training sessions. IW has done training in the past and has shown evidence to BW, however they will implement more training. May-17 Occupational Safety and Health Worker Protection Approximately 14 per cent of all machines are missing eye guards, 53 per cent are missing pulley guards and 65 per cent of single needle machines are missing finger guards. Ensure that the system to monitor the availability of machine guards is operational and effective. Liaise with the head mechanic to ensure that the guards are replaced on time. Meetings have been organized with the mechanics and production managers to strengthen the monitoring system. Additional training will also be provided to workers. May-17 Occupational Safety and Health Health Services and First Aid Workers who are exposed to work-related hazards have not received periodic free health checks. Ensure that workers who are exposed to work-related hazards receive free periodic health checks. The process has been established and workers exposed to chemicals received 3 health medical checks on a yearly basis. May-17 Occupational Safety and Health Health Services and First Aid No annual medical checks were provided to workers. May-17 Compensation Overtime Wages Attendance records do not reflect the actual hours worked for workers in the sewing line. Provide free annual medical checks for workers. Followup with OFATMA to ensure that they either provide this service or refer the factory to another organization that can provide free medical checks. Ensure that attendance records reflects exactly the working time for all workers. Pay workers 50 percent above the normal wage for all ordinary overtime hours worked. The process has been established and 70% of workers has received annual checks. The factory has incorporated the medical checks in their Health care policy. Management provided evidence that attendance records show all worked hours including overtime and workers are accurately compensated. May-17 Compensation Wage Information, Use and Deduction Inaccurate Payroll records. Time records were inconsistent with the payrolls for overtime hours. Record overtime hour worked, also, keep only one accurate payroll records. The factory technician finalized the system changes to reflect the accurate overtime. May-17 Compensation Paid Leave Payments for sick leaves are based on the minimum wage instead of average earnings. Ensure that payments for sick leaves are based on workers average earnings. Sick leaves are based on workers average earnings. May-17 Compensation Paid Leave Payments for maternity leaves are based on the minimum wage instead of average earnings. Ensure that payments for maternity leaves are based on workers average earnings. Maternity leaves are based on workers average earnings. 187 May-17 Compensation Social Security and Other Benefits ONA contributions are based on a fixed salary for all workers. Ensure that ONA payment is based on the basic salary instead of a fixed salary for all workers. Factory has adapted its method of paying ONA, starting October 2018, to reflect exactly the presence of the workers instead of the 5-day week method which was adopted in an effort not to penalize the workers. May-17 Compensation Social Security and Other Benefits ONA contributions are based on a fixed salary for all workers. Ensure that ONA payment is based on the basic salary for all workers. Factory has adapted its method of paying ONA, starting October 2018, to reflect exactly the presence of the workers instead of the 5-day week method which was adopted in an effort not to penalize the workers. May-17 Compensation Social Security and Other Benefits Employer contribution to OFATMA for work-related accident insurance. Ensure that employers' contribution to OFATMA for work-related accident insurance is based on workers' basic salary. As per the law, IW pays based on the workers wages. May-17 Compensation Social Security and Other Benefits Workers' contributions to OFATMA for maternity and health insurance. Collecting and forwarding of workers' contributions to OFATMA for maternity and health insurance. The factory is in the process of registering workers to OFATMA for maternity and health insurance. May-17 Compensation Social Security and Other Benefits Employer contribution to OFATMA for maternity and health insurance. Register with OFATMA for maternity and health insurance services. May-17 Occupational Safety and Health Chemicals and Hazardous Substances Inventory of chemicals and hazardous substances used in the workplace is not up to date. Keep an inventory of chemicals and hazardous substances used in the workplace. The factory is in the process of registering workers to OFATMA for maternity and health insurance. The factory keeps an inventory of chemicals used in the workplace. May-17 Occupational Safety and Health Chemicals and Hazardous Substances Several unlabelled containers of chemical found throughout the workplace. - Label all containers of chemicals and hazardous substances - Incorporate the importance of labelling containers into the training on chemical substances - Monitor the labelling of containers - Have someone in charge for transferring the chemicals The factory bought new containers and labelled them before giving them to workers. The compliance manager is in charge to monitor OSH related matter. 188 May-17 Occupational Safety and Health Chemicals and Hazardous Substances Chemicals and hazardous substances improperly stored. Store chemicals and hazardous substances in the designated chemical warehouse. All chemicals have been rearranged and labelled and stored in the chemical room May-17 Occupational Safety and Health Chemicals and Hazardous Substances No MSDS' were posted for chemicals such as rust out remover and spray paint in the laboratory room of Building 30. - Make sure to have the MSDS for all hazardous chemicals used in the workplace - Translate the MSDS in local language as needed MSDS are available for all chemicals used in the workplace. MSDS are available in local language. May-17 Occupational Safety and Health Chemicals and Hazardous Substances Assessing, monitoring, preventing and/or limiting workers' exposure to hazardous substances. -Measure workers' exposure to hazardous substances. -Isolate areas where hazardous substances are used -Ensure that these areas are well ventilated. Corporate Management is elaborating a technical document to monitor the workers 'exposure to hazardous substances and should be ready in 2 weeks. May-17 Occupational Safety and Health Chemicals and Hazardous Substances Washing facilities or cleansing materials are not available in the event of chemical exposure. Provide adequate washing facilities and cleansing materials in the event of exposure to hazardous chemicals. Eye wash station installed in adequate location near spot cleaning area. May-17 Occupational Safety and Health Worker Protection Train and encourage workers to use PPE, machines and equipment safely. The factory scheduled a training for the Maintenance team with an expert on Boiler Safety and procedures. May-17 Occupational Safety and Health Worker Protection No documented evidence of training on the safe use of boilers were provided to the assessors at the time of assessment. Guards are not installed on all dangerous parts of machines and equipment. More than 30 percent of all machines in Building 30 were missing pulley guards. Install proper guards and maintained on all dangerous parts of machines and equipment. The factory completed the installation of the pulley guards on 70 percent of the sewing machines. A new procedure to make each operator (Mechanics, Supervisors, Workers) involved in the use of the sewing machines aware of his/her responsibility is sent to top management for approval. May-17 Occupational Safety and Health Worker Protection One uncovered electrical box with exposed wires in a small warehouse near the boiler room of Building 29. Moreover, electrical outlets were uncovered in Buildings 29, 30 and 10 Ensure that electrical wires, cables, switches, plugs and equipment are properly maintained. The electrical box in the boiler room of Building 29 was covered while the audit. The chief of the maintenance is using a check list for internal audit May-17 Occupational Safety and Health Worker Protection One electrical box in the boiler room of Building 29 was missing a hazard warning sign. Identify electrical hazards and post safety warnings in the workplace. The warning sign was posted on electrical box in the boiler room of Building 29.The chief of the maintenance is using a check list for internal audit 189 May-17 Occupational Safety and Health Working Environment Workplace temperature exceeded BW recommended limit of 30 C. Improve the temperature levels throughout the workplace. Additional fans have been installed throughout facility and temperatures are being monitored. May-17 Occupational Safety and Health Working Environment Workplace lighting is under Better work recommended limits in sewing and packing sections. Increase the light level in the indicated areas. The factory replaces defective bulbs on a weekly basis to avoid those types of issues. Check lists are used for internal audits. Factory will comply to this requirement. May-17 Occupational Safety and Health Welfare Facilities Insufficient number of toilets. Ensure that the factory has 13 functioning toilets for men and 43 functioning toilets for women. SONAPI has already come to factory for assessment and will start building new bathrooms at the end of this month (November 2018). May-17 Occupational Safety and Health Health Services and First Aid insufficient number of medical staff. Hire additional medical staff, at least 5 nurses and 3 doctor's visit per week. Factory employs 3 full-time nurses, 1 doctor present 3 times a week and on-call the rest of the week, and one supervisory doctor who visits frequently and whenever called upon. May-17 Occupational Safety and Health Health Services and First Aid Access to one first aid box in Building 10 was obstructed by boxes. Ensure first aid box are accessible and remain unobstructed. First aid boxes in Building 10 are accessible. The OSH committee will ensure that this point has a permanent follow up. May-17 Occupational Safety and Health Emergency Preparedness No smoke detectors were observed in the trim warehouse of Building 30. Install fire detection and alarm system. Smoke detector was installed in the warehouse of Building 30. May-17 Occupational Safety and Health Emergency Preparedness Operating procedures for boilers were not available. Ensure that the procedure is available and train operators on the safe use of boilers. Operating Procedures for the boilers are available. 6 operators in the maintenance department were trained on Boiler safety and usage on March 2018. May-17 Working time Regular Hours Inaccuracy of the attendance records. Ensure that the attendance records reflects exactly the working time. The company complies with this requirement. Attendance records of all workers reflects exact working hours and starting October 29th 2018, workers get paid double their normal wage for hours worked after 6:00 PM. 190 May-17 Working time Overtime Excessive overtime. Ensure that workers do not exceed the legal limit of overtime hours. Final auditors and operators in the cutting section are now working on one shift instead of two shifts. This change has regularized their working time accordingly. May-17 Occupational Safety and Health Welfare Facilities The factory does not have an appropriate eating area. Provide eating area that can accommodate all the workers. Full capacity Cafeteria is provided by Sonapi and accessible to all workers. Additionally, factory is keeping on premises 3 designated eating area for workers. May-17 Discrimination Interference and Discrimination Termination or non-renewal of workers employment contract due to union membership or activities. May-17 Occupational Safety and Health Emergency Preparedness Several fire extinguishers were found missing, obstructed or without identification signs. Reinstate the 32 terminated workers including the 11 terminated union officers with compensation for back pay. Ensure to that all extinguishers locations are marked and accessible. All fire extinguisher are marked and accessible. 191 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Val d'Or Apparel Mfg. S.A Port-au-Prince 1218 Sep-14 Oct-18 Sep-17 Advisory and Training Services 29-Mar-19 Bipartite Committee to discuss security around factory and toilet reparations. 18-Mar-19 Factory visit conduct OSH tour to verify sustainable correction of OSH findings with compliance manager. Factory visit to facilitate bipartite meeting between union committee members & management. 25-Jan-19 25-Jan-19 17-Jan-19 Bipartite Committee to discuss working conditions. Bipartite Committee to discuss investigations into worker absences from work stations. Factory visit to discuss verbal abuse remediation action plan with General Manager. Meeting to discuss Improvement Plan with Compliance Officer 3.Factory visit to conduct OSH tour for hazard hunting with Compliance Officer 18-Dec-18 7-Dec-18 4-Dec-18 28-Nov-18 27-Nov-18 14-Nov-18 25-Oct-18 8-Oct-18 Bipartite Committee to discuss worker reactions on OFATMA deductions. Workshop on gender challenges in the workplace Training of Trainer supervisory Skills (ToT SST) Bipartite Committee to discuss social security required deductions on workers. Training in Sexual Harassment with Share Hope Building Bridges workshop to discuss implementation of long-term sectorial strategies. Bipartite Committee to discuss internal working rules violations. Meeting to discuss Sexual harassment policy, the Improvement Plan and the first progress report with Compliance manager. Meeting with union to discuss Incentive plan, worker selection for week-end shift and allegation of verbal abuse. ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT DETAILS OF NON COMPLIANCE IMPROVEMENT PRIORITIES REMEDIATION EFFORTS MONTHS All MSDS are posted in local language. 5 Assessment October 2018 Oct-18 Occupational Safety and Health Chemicals and Hazardous Substances The chemical warehouse did not have all the required MSDS Provide MSDS for all chemicals or hazardous substances used in the workplace Oct-18 Compensation Social Security and Other Benefits The factory calculates employer's ONA contributions based on the minimum wage instead of the base salary. Ensure that ONA employer contributions are based on 6% of basic salary as defined in the Haitian labour code. 5 192 Oct-18 Compensation Social Security and Other Benefits The factory calculates workers' ONA contributions based on the minimum wage instead of the base salary. Ensure that ONA contributions is based on the basic salary instead of the minimum wage 5 Oct-18 Compensation Social Security and Other Benefits Total amount declared to OFATMA was less than the total amount of salaries effectively paid to workers for the fiscal year 2016-2017. Employer should ensure that the total amount declared to OFATMA is the total amount of salaries effectively paid to workers for the fiscal year. 5 Oct-18 Compensation Social Security and Other Benefits The factory calculates OFATMA maternity and health insurance contributions based on the minimum wage instead of the base salary. Ensure 6% basic salary is used when calculating maternity and health insurance contributions as defined in the labour code. 5 Oct-18 Compensation Social Security and Other Benefits The factory calculates OFATMA contributions based on the minimum wage instead of the base salary. Ensure that worker contributions are calculated based on 6% of worker base salary instead of minimum wage. 5 Oct-18 Contract and Human Resources Dialogue, Discipline and Disputes Supervisors use inappropriate and abusive language toward the workers. Include zero tolerance policy in internal rules and establish investigation procedures on verbal abuse Communicate results to concerned parties Participate in training on proper workplace communication 5 Oct-18 Occupational Safety and Health OSH Management Systems Occupational safety and health assessment reports were not done on a regular basis and does not consult with the workers during the assessment. Ensure regular internal assessment on a monthly basis. Consult with the workers during the assessment and also inform them of the results. 5 Oct-18 Occupational Safety and Health OSH Management Systems Work related accidents were not submitted to OFATMA on a monthly basis. Assign responsible person to submit OFATMA work related accidents on a monthly basis. Include in factory OSH internal assessments to verify consistency. Responsible person was assigned and verification is done through internal assessment by the factory. 5 193 Oct-18 Occupational Safety and Health Chemicals and Hazardous Substances Incomplete inventory of chemicals and hazardous substances used in the workplace Assign responsible persons for updating inventories of hazardous substances in the various locations where they are stored or used. Management added missing chemical to the inventory 5 Oct-18 Occupational Safety and Health Chemicals and Hazardous Substances Unidentified container of oil , Thinner and liquid soap used in the mechanic workshop. Assign clear responsibility for the labelling of the chemical and hazardous substances. Identify all containers used in the workplace according to specifications. Responsibility was assigned and containers are labelled 5 Oct-18 Occupational Safety and Health Chemicals and Hazardous Substances No MSDS were available for chemicals stored in the chemical warehouse. Identify MSDS for all chemical products used in production and ensure availability in local language where such products are being used. All MSDS are posted in local language. 5 Oct-18 Occupational Safety and Health Chemicals and Hazardous Substances There was no eye wash station in the welding workshop where chemicals were stored at the time of assessment visit. Ensure availability of eyewash where chemicals are being used including but not limited to the welding shop 5 Oct-18 Occupational Safety and Health Worker Protection Chairs provided to workers in the school section and packing area were missing back rest.. Ensure that all chairs used on the factory floor comply with their respective ergonomic requirements including but not limited to proper backrest. 5 Oct-18 Occupational Safety and Health Worker Protection Entry point of electrical panels were not properly sealed in the cutting area and junction boxes were not covered in the fabric storage. 1. Ensure that all entry point of electrical panels are properly sealed 2. Ensure that junction boxes are covered. 5 Oct-18 Occupational Safety and Health Worker Protection 1 electrical panel was missing hazard sign in the boiler room. Ensure that electrical panels have hazard signs including but not limited to the one located in the boiler room All electrical panels have hazard signs. 5 194 Oct-18 Occupational Safety and Health Working Environment Temperatures exceed 31 C in all sections. 1. Use electrical exhaust fans or cooling system 2. Ensure that the air-flow to and from the fans is not blocked 3. Make sure that all fans are wellmaintained and regularly cleaned 4. Monitor workplace temperature on a regular basis Oct-18 Occupational Safety and Health Working Environment Insufficient lighting in the cutting section Improve lighting in the cutting section through new bulb installations or penetration of natural light. Oct-18 Occupational Safety and Health Welfare Facilities With its current workforce, the factory should have 8 functioning toilets for men and 68 functioning toilets for women. Have 8 functioning toilets for men and 68 functioning toilets for women as indicated in the Haitian labour code. 5 Oct-18 Occupational Safety and Health Welfare Facilities Eating area can accommodate approximately 30 percent of its workforce at once. Enter into consultation with worker representatives and industrial park management to find possible solutions for sufficient eating space. 5 Oct-18 Occupational Safety and Health Health Services and First Aid Pregnant workers are not provided break as described by the law. Ensure that pregnant women benefit from additional breaks as required by the law. Oct-18 Occupational Safety and Health Health Services and First Aid Factory of this size must have a permanent onsite medical service, with at least 6 nurses and 3 doctor's visits per week. Hire a permanent onsite medical service made up of at least 6 nurses and 3 doctor's visits per week. 5 Oct-18 Occupational Safety and Health Health Services and First Aid Found missing products in all first aid boxes Designate responsible person in OSH committee to perform regular inventory of all first aid boxes. 5 Oct-18 Occupational Safety and Health Emergency Preparedness Training area is not reflected in the current evacuation plan. Update current plan to match actual lay out of factory floor including but not limited to training area 5 Oct-18 Occupational Safety and Health Emergency Preparedness Emergency exit next to the fabric warehouse and one emergency exit in the training area were locked during working hours. Ensure that emergency exits and escape routes remain unblocked during working hours 5 5 Factory purchased new light bulbs. Pregnant women receives required additional breaks. 5 5 195 Oct-18 Occupational Safety and Health Emergency Preparedness Fire drill is not being held every 6 months as recommended. Ensure that fire drills are completed twice yearly 5 Assessment September 2017 Sep-17 Compensation Overtime Wages Workers of the cleaning section were not paid 50 percent above the normal wage for all ordinary overtime hours worked. Comply with the law regarding the overtime payment Management has eliminated much of overtime. All occasional overtime are paid per recent assessment. Sep-17 Compensation Premium Pay Workers were not paid 50 percent above the normal wage for regular hours worked on legally mandated holidays. Comply with law regarding the overtime payment The factory changed the calculation method to pay premium on overtime hours. Sep-17 Compensation Paid Leave Payments for non-working holidays are based on the minimum wage instead of average earnings. . Comply with the law regarding the payment for non-working Holidays Payment is now based on average earnings. Sep-17 Compensation Paid Leave Payments for weekly rest days are based on the minimum wage instead of average earnings. Comply with the law regarding the payment for weekly rest day Sep-17 Compensation Social Security and Other Benefits The factory calculates ONA contributions based on the minimum wage instead of the base salary. Comply with the law regarding ONA's contributions Sep-17 Compensation Social Security and Other Benefits ONA deductions are based on the payroll of the last 2 weeks of each month instead of the full month as required by law. Ensure that ONA contributions is based on the monthly base salary Sep-17 Compensation Social Security and Other Benefits The factory has paid the employer contribution for OFATMA for maternity and health insurance. Register with OFATMA for maternity and health insurance. Factory is registered. Sep-17 Compensation Social Security and Other Benefits The factory has not paid the workers'contribution OFATMA for maternity and health insurance. Management said that the registration is in process. Register with OFATMA for maternity and Health Insurance. Factory is registered. Sep-17 Contract and Human Resources Employment Contracts Workers interviewed revealed that their contract allowed a 35 minutes lunch break instead of the 1 hour described in the internal work rules. Align contracts with internal work rules Contracts terms are now aligned with provisions of internal work rules related to the lunch break. 196 Sep-17 Contract and Human Resources Contracting Procedures Foreign worker's contracts do not specify the period of employment and the hours of work. Foreign workers are not covered by OFATMA for work related accidents. Specify the type of employment in the foreign workers' contracts. Ensure that all workers are covered by the OFATMA for work related accidents. Sep-17 Contract and Human Resources Dialogue, Discipline and Disputes Incidents of verbal abuse by supervisors and managers who use offensive words. Plan training for supervisors and managers on supervisory skills Sep-17 Occupational Safety and Health Chemicals and Hazardous Substances The factory only has an outdated list of chemicals and does not maintain an updated inventory. Maintain a detailed inventory of the chemicals used in the workplace. A complete inventory of chemical inventory is maintained by the compliance officer. Sep-17 Occupational Safety and Health Chemicals and Hazardous Substances Labelling practices does not comply with the requirements stipulated in the national law as the labels are only available in a foreign language. Label all containers used in the workplace in local language Containers of chemical were observed to be labelled by assigned person. Sep-17 Occupational Safety and Health Chemicals and Hazardous Substances The factory did not show evidence of training for workers who use chemicals and hazardous substances. Provide training to workers who use chemicals and hazardous substances Training was provided Sep-17 Occupational Safety and Health Worker Protection Management has not provided proper masks and goggles to workers in the boiler area. Provide proper Personal protective equipment to workers. Provide goggles to workers in the boiler area Sep-17 Occupational Safety and Health Worker Protection 70 percent of workers in the sewing area were not using the installed safety eye guards. Provide training on the using of sewing machine guards. Sep-17 Occupational Safety and Health Worker Protection Pregnant women were observed in chairs without backrests. Ensure that all chairs used on the factory floor comply with their respective ergonomic requirements including but not limited to proper backrest. Sep-17 Occupational Safety and Health Working Environment Temperature exceed 31 C in all sections Sep-17 Occupational Safety and Health Welfare Facilities With its current workforce the factory should have 12 functioning toilets for men and 67 for women. Use electrical exhaust fans or cooling system. Monitor workplace temperature on a regular basis. Comply with legal requirements regarding the number of toilets Foreign worker's contracts specify terms of employment. Training was provided 197 Sep-17 Occupational Safety and Health Health Services and First Aid The factory did not show evidence of medical checks conducted for workers within the first three months of hiring. Conduct medical checks conducted for workers within the first three months of hiring. Sep-17 Occupational Safety and Health Health Services and First Aid The factory did not provide health checks to workers who have been exposed to work-related hazards. Provide health checks to workers who have been exposed to work-related hazards Sep-17 Occupational Safety and Health Health Services and First Aid The factory did not show evidence of annual medical checks for workers. Provide annual health checks to workers Sep-17 Occupational Safety and Health Health Services and First Aid Factory of this size must have a permanent onsite medical service, with at least 6 nurses. Have a permanent onsite medical service, with at least 6 nurses Sep-17 Occupational Safety and Health Emergency Preparedness Fire extinguishers were obstructed by boxes in multiple locations 1. Conduct daily checks by OSH focal points. 2. Remind supervisors of OSH responsibilities 3. Ensure that fire protection equipment are not obstructed. Sep-17 Occupational Safety and Health Emergency Preparedness Aisles obstructed by fabric rolls and boxes were observed at the fabric warehouse and in modules 10 and 21. Conduct daily checks by OSH focal points. Remind supervisors of OSH responsibilities. Ensure that aisles are not obstructed. Sep-17 Occupational Safety and Health Emergency Preparedness Assessors found 2 closed emergency exits Leave door open with security guards in attendance in order to open fully in the event of an evacuation Sep-17 Occupational Safety and Health Emergency Preparedness Factory does not maintain nor follow operation and maintenance procedures for the boiler. Obtain original maintenance manual for boiler. Conduct and document all maintenance in an appropriate log accordingly. Sep-17 Working Time Overtime Factory exceeds the legal overtime limit for workers in the production, cleaning and cut control areas up to 170 hours for the period from June to August 2017. No longer required as per the new law. Focal points conducts random checks with assistance from supervisors to minimize obstruction. No longer required as per the new law. 198 Sep-17 Working Time Overtime No authorization was available for overtime hours worked during September 2017. Follow up with ministry labour on overtime authorization request No longer required as per the new law. 199 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Date of last two Better Work assessments: The Willbes Haitian 2A S.A. Port-au-Prince 1315 Aug-10 Jul-18 Mar-17 Advisory and Training Services Meeting with management on factory general updates and concerns. Revision of improvement plan. Documentation review. Factory tour with OSH committee 1-Mar-19 members to validate the correction. 14-Dec-18 Meeting with management on the improvement plan.Meeting with OSH committee members for a recap of the improvement throughout the year. 27-Nov-18 Sexual Harassment prevention training Meeting with the compliance team on the Improvement plan and remediation efforts. 13-Oct-18 Meeting with trade union leaders and HR manager on the concern of false Medical certificates for sick leave and OFATMA cards. ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT DETAILS OF NON COMPLIANCE IMPROVEMENT PRIORITIES REMEDIATION EFFORTS MONTHS Jul-18 Occupational Safety and Health Assessment July 2018 OSH Management Systems The employer has not developed any mechanism to ensure cooperation on OSH matters. Ensure that OSH committee is involved in developing OSH priorities and procedures. The factory has an active OSH committee. Meeting are being carry out on a monthly basis. 5 Jul-18 Occupational Safety and Health OSH Management Systems OSH policy is not signed by top management. Update the OSH policy with the participation of the worker representatives. The OSH Policy has been presented and explained to the OSH committee. Both workers and management representatives signed the policy. 5 Jul-18 Occupational Safety and Health Worker Protection No gloves provided to workers in the mechanic shop. Provide gloves to the workers of the mechanic shop. Ensure that workers are provided with necessary PPE. Train workers to use the provided PPE Workers at the mechanic shop were provided with gloves. 67 Jul-18 Occupational Safety and Health Worker Protection Standing workers in the packing area of building 43 did not have shock absorbing mats. Provide shock absorbing mats to standing workers. All workers in standing position were provided with standing mats at building 43. 5 200 Jul-18 Occupational Safety and Health Worker Protection Electrical box poorly maintained with lose wires covered with black tape in the mechanic shop of building 42. Maintain regularly the electrical installations. Jul-18 Occupational Safety and Health Working Environment Temperature exceeded 30C in the packing, pressing, cutting and quality section. Keep the temperature level to a maximum of 30 C. Jul-18 Occupational Safety and Health Working Environment The level of lighting was inadequate in Pressing section202 Lux where the recommended level is 500 Lux. Ensure that light level is adequate the pressing section. Jul-18 Occupational Safety and Health Health Services and First Aid Insufficient number of medical staff. Jul-18 Occupational Safety and Health Health Services and First Aid Listed items missing in the first aid box. Have a permanent medical staff with 6 nurses and 3 doctor's visit. Have adequate first aid box available for the workers with necessary products. Mar-17 Occupational Safety and Health Chemicals and Hazardous Substances Chemicals are not properly stored. Ensure that chemicals are properly stored. Mar-17 Occupational Safety and Health Chemicals and Hazardous Substances No MSDS' were posted for chemicals such as retarder, thinner, HP control and EBD cleaner in the chemical room. Post MSDS' were chemicals are All chemical substances were used. Ensure that they are provided with the MSDS. clearly labelled. Mar-17 Occupational Safety and Health Chemicals and Hazardous Substances Documented evidence of actions taken by management to control and oversee workers' exposure to chemicals and hazardous substances were unavailable during the assessment. Keep records of awareness and The factory keeps records training provided to workers. of all training provided to Post awareness message on workers. appropriate places throughout the workplace. Mar-17 Occupational Safety and Health Chemicals and Hazardous Substances No eye wash station in the spot cleaning area of building 45. Provide washing facility where needed, especially in the spot cleaning. Electrical box's internal wiring and interrupters at the mechanic shop was properly covered with a transparent, protective material to avoid electrical shock hazard. Maintenance personnel was properly trained to keep it in place at all times. 82 5 Factory installed additional lamps. 5 82 Facility ensured that the content of 1 first aid kit in building 42 matches with the items included in the check list. Alcohol, scissor and forceps were added. Assessment March 2017 Facility ensured to have all chemical substances properly stored. Workers received instructions on storage methods. Facility installed the eye wash station at the spot cleaning room. 5 201 Mar-17 Occupational Safety and Health Worker Protection In the inspection area, workers using thinner were provided with protective masks. Provide mask to workers that are manipulating chemicals. Provide training to exposed workers on the usage of protective equipment. This practice was stopped immediately. All work related to chemicals substances is been done at the spot cleaning area where workers are provided with the necessary PPE's to perform their duties. All the machines have their necessary guards. Training completed for supervisors on OSH in September 2017. Mar-17 Occupational Safety and Health Worker Protection No evidence of training provided to workers to properly use personal protective equipment and machines. Ensure that all machines have their necessary guards. Train workers and supervisors on OSH matters. Mar-17 Occupational Safety and Health Worker Protection 85 percent of single needle machines in buildings 41 and 42 are missing finger guards. Ensure that all machines have their necessary guards All single needle machines were provided with its needle guards Mar-17 Occupational Safety and Health Worker Protection Several uncovered electrical boxes with exposed wires and cables. Electrical equipment were improperly installed and stored in the parking and pressing sections of building 43. Regularly maintain electrical equipment. Keep a log of weekly inspection. All electrical boxes were already covered. Mechanics received a training on Occupational Safety and Health. Mar-17 Occupational Safety and Health Welfare Facilities Insufficient number toilets for women. Comply with the law regarding the number of functioning toilets. 22 additional toilets have been added. The factory does not have more plans to increase the number of toilets as we comply with International standards. Building additional toilets would be hard due to the lack of space. Mar-17 Compensation Paid Leave Payment for non-working holidays are based on the minimum wage instead of average earnings. Ensure to pay non-working holidays based on average earnings. The payroll system has already been changed, so that the non-worked holidays are paid based on the average earnings. Mar-17 Compensation Paid Leave Payment for weekly rest days are based on the minimum wage instead of average earnings. Ensure that payments for weekly rest days are based on the average earnings. The payroll system has already been changed, so that the weekly rest days are paid based on the average earnings. Mar-17 Compensation Paid Leave Payment for sick leave are based on the minimum wage instead of average earnings. Ensure that payments for sick leave is based on the average earnings. Mar-17 Compensation Social Security and Other Benefits Employer's contribution to ONA is based on the minimum wage instead of the base salary. Ensure that ONA contributions are based on base salary. Payment system has been reviewed and all the necessary adjustments have been made. Sick leave is paid based on average earnings. The contribution to ONA for all Willbes factories is paid based on the workers' base salary. 202 Mar-17 Compensation Social Security and Other Benefits Workers' contributions to ONA, is based on the minimum wage instead of the base salary. Ensure that ONA contributions are based on base salary. ONA contributions are based on base salary. Facility properly collects and forwards workers' contributions to ONA. Mar-17 Occupational Safety and Health Health Services and First Aid No systematic medical checks were arranged for workers exposed to work-related hazards. Arrange, at least, twice a year, medical checks for workers exposed to work-related hazards. All mandatory medical checks for all Willbes factory workers have started already. The plan will take around 4 months. Additional checks are being requested to OFATMA as well. Also, the factory changed the doctor's contract to full-time and started with the medical checks. Mar-17 Occupational Safety and Health Health Services and First Aid No systematic annual medical checks for all workers. Arrange, at least, once a year, medical checks for all workers. Mar-17 Occupational Safety and Health Health Services and First Aid Insufficient medical staff. Hire the appropriate number of medical staff according to their workforce. Mar-17 Occupational Safety and Health Emergency Preparedness Fire alarms switches obstructed in buildings 42 and 43. No smoke detectors in buildings 41, 44 and 46. Ensure to have appropriate fire fighting equipment. Install smoke detectors in buildings 41,44,46. All mandatory medical checks for all Willbes factory workers have started already. The plan will take around 4 months. Additional checks are being requested to OFATMA as well. Also, the factory changed the doctor's contract to full-time and started with the medical checks Facility has an additional clinic on site. Management is making all the arrangement in order to increase our medical staff. Facility took immediate action on these findings. Fire alarms are properly maintained and accessible, switches are properly covered. Smoke detectors will be installed shortly. Mar-17 Compensation Social Security and Other Benefits The factory has not registered with OFATMA for maternity and health insurance. Register with OFATMA for maternity and Health insurance. The Willbes Haitian S.A has initiated the registration process with OFATMA, by paying the Company's contribution. The factory forwarded OFATMAs' deduction for the month of September 2017 203 Mar-17 Compensation Social Security and Other Benefits The factory has not registered with OFATMA for maternity and health insurance. Register with OFATMA for maternity and Health insurance. The Willbes Haitian S.A has initiated the registration process with OFATMA, by paying the Company's contribution. The factory forwarded OFATMA's deductions for the month of September 2017 Mar-17 Occupational Safety and Health Chemicals and Hazardous Substances At the time of the assessment visit, there was no updated inventory of chemicals and hazardous substances used in the workplace. Keep an updated inventory of chemicals and hazardous substances used in the workplace. Facility normally keeps an inventory of all chemicals used; the records were not updated due to a shipment received near the audit date and chemicals were not on inventory. The chemicals inventory logbook will be updated and kept normally going forward. Mar-17 Occupational Safety and Health Chemicals and Hazardous Substances Unidentified chemicals. Labelling of chemicals in foreign languages. Label all containers of chemicals in Creole- Train mechanics on Occupational Safety and Health concerns. Mar-17 Occupational Safety and Health Emergency Preparedness Mar-17 Occupational Safety and Health Emergency Preparedness Missing fire extinguishers in the cutting section of buildings 45 and 42 on the mezzanine of building 43. Several fire extinguishers were obstructed. Inaccuracy of the evacuation plan. Regularly maintain fire extinguishers. Keep an OSH checklist to update regularly. Perform regularly internal OSH assessment. Post the updated evacuation plan. Equip exits with emergency exit lights. Accordingly mark the floor with the new layout. Facility ensured to have all chemical containers properly labelled and identified in local language in all factories areas. Fire extinguishers were installed in the designated areas and properly maintained. Mar-17 Occupational Safety and Health Emergency Preparedness One exit was locked during working hours. Keep the exits accessible during working hours. The evacuation plan has been updated according to the new layout of the floor. New emergency exit lights have been purchased and installed Facility already has emergency exit accessible. Construction works already stopped 204 BETTER WORK HAITI – 18TH SYNTHESIS REPORT Factory: Location: Number of workers: Date of registration: Date of last two Better The WILLBES Haitian III S.A Port-au-Prince 763 Aug-10 Jul-18 May-17 Advisory and Training Services 1-Mar-19 Factory visit 1 Meeting with management on factory general updates and concerns. Revision of improvement plan. Documentation review. Factory tour with OSH committee members to validate the correction. 14-Dec-18 27-Nov-18 13-Oct-18 Factory visit to discuss on the improvement plan. Meeting with OSH committee members for a recap of the improvement throughout the year. Sexual Harassment in the events of Share Hope Factory visit to discuss on the improvement plan and remediation efforts. Meeting with trade union and HR manager to discuss on falses medical certificates for sick leave provided by workers and OFATMA cards- Trade union and HR manager. ASSESSMENT COMPLIANCE CLUSTER COMPLIANCE POINT DETAILS OF NON COMPLIANCE Jul-18 Compensation Social Security and Other Benefits Late ONA payment. Management ensured that ONA payment is done between the first 10 working days of each month. Management ensured that ONA payment is done between the first 10 working days of each month. 26 Jul-18 Compensation Social Security and Other Benefits Late ONA payment. Ensure ONA contributions is paid within the first 10 working days of each month for the previous month. Management ensure that ONA payment is done between the first 10 working days of each month. 26 Jul-18 Occupational Safety and Health OSH Management Systems The employer has not developed any mechanism to ensure cooperation on OSH matters. Have a functioning OSH committee. Hold regular OSH committee meetings. Facility has records of OSH assessment on a monthly basis. Osh committee regularly meets on a monthly basis. 2 IMPROVEMENT PRIORITIES REMEDIATION EFFORTS MONTHS Assessment July 2018 205 Jul-18 Occupational Safety and Health OSH Management Systems The factory has a written OSH policy which is not signed by top management. Consult workers representative in any change related to OSH policy. The factory has an OSH policy signed by top management. The OSH policy was communicated to Workers representative.The workers representatives in the OSH committee signed the policy. 2 Jul-18 Occupational Safety and Health Chemicals and Hazardous Substances The inventory does not include all the hazardous substances used in the workplace. Keep an inventory that includes all chemicals used in the workplace. All chemical used at the facility are included in the chemical inventory. KCC paint and EYB 143 won't be in the chemical inventory as the factory does not use it anymore. 2 Jul-18 Occupational Safety and Health Chemicals and Hazardous Substances Unidentified containers of chemicals. Label all contained used in the workplace. Train relevant workers on chemical handling. All chemical containers were properly labeled such machine oil and diesel tank. The chemical K7M is not used in the area anymore. 16 Jul-18 Occupational Safety and Health Chemicals and Hazardous Substances No MSDSs were available in the mechanic shop of building 34 were chemicals are used. Ensure that the MSDS are available for all the chemicals and hazardous substances used in the workplace. Facility ensured to have MSDS for chemical product Al-Con 200. We do not normally used KCC paint nor EYD 143. 26 Jul-18 Occupational Safety and Health Chemicals and Hazardous Substances No eye wash station in the mechanic shop of building 34 where chemicals and hazardous substances are used. Ensure washing facilities are available in the area where chemicals and hazardous substances are used. An eye wash station wont be installed at the mechanic shop. Facility decided to remove chemical from this area. 2 Jul-18 Occupational Safety and Health Worker Protection Missing pulley guards. Provide all the machines with the necessary guards. Facility ensured to install pulley guards on required machines. 26 Jul-18 Occupational Safety and Health Worker Protection One uncovered electrical panel with exposed wires in the mezzanine of building 34. In the generator room the batteries terminals were missing insulation covers. Maintain the electrical installations regularly. Ensure the electrical installation remain unobstructed. The electrical panel with exposed wires in B C Grades ( mezzanine ) of building 34 was properly covered. 16 206 Jul-18 Occupational Safety and Health Worker Protection One electrical panel found missing appropriate safety warnings. Post hazard sign on all electrical panel. Electrical control panel at the mezzanine was provided with warning sign. 16 Jul-18 Occupational Safety and Health Working Environment Level of lighting is inadequate in packing section. Better Work recommends a minimum of 300 lux for this pressing section Better Work recommends a minimum of 500 lux for sewing, cutting, packing section. Better Work recommends a minimum of 750 lux for trimming, inspection section Facility goes beyond Better Work recommendations of lux for all the working sections. Internal audits are performed regularly to ensure that the light level level is appropriate. 16 Jul-18 Occupational Safety and Health Welfare Facilities Insufficient number of toilets for women. Ensure to have an adequate number of toilets. With its current workforce, the factory should have 47 functioning toilets for women. Factory does not have any plans for installing additional toilets. 81 Jul-18 Occupational Safety and Health Health Services and First Aid The factory does not provide systematic health checks to workers within the first three months of hiring. Arrange health checks for workers within the first three months of hiring. HR Manager was properly trained. Systematic health checks to workers is provided within the first three months of hiring. 81 Jul-18 Occupational Safety and Health Health Services and First Aid Insufficient number of onsite medical staff. Ensure to have a permanent onsite medical staff of 4 nurses and 3 doctor's visits per week. Factory does not have plans to increase medical staff. 81 Jul-18 Occupational Safety and Health Health Services and First Aid One expired product found in two first aid boxes.. Ensure that the first aid box are inspected on a regular basis. Replace expired products. Expired products such as Pro-Dovidine in 2 first aid boxes were removed immediately. Facility will ensure to inspect all first aid kits on a weekly basi. This issue was corrected during the assessment. 2 Jul-18 Occupational Safety and Health Emergency Preparedness One fire extinguisher found with low pressure and one found overcharged. Ensure that the fire-fighting system are maintained on a regular basis. Management ensured to install a well maintained fire extinguisher at the material warehouse and another in cutting department. 2 207 Jul-18 Occupational Safety and Health Emergency Preparedness Evacuation plans have not been updated in building 34. Upgrade the evacuation plan accordingly. Ensure that mezzanine is included with indication of escape routes for it. Evacuation plan is ok for the factory (Sewing and Cutting department). A separate evacuation plan was added to the mezzanine. 16 Jul-18 Working Time Regular Hours The factory's working hours for all shifts including break time were not posted by the employer. Post the working time including break time inside the workplace. Working time and break time is posted inside the workplace. 16 Jul-18 Working Time Leave The policy on the breastfeeding break is not fully applied. Ensure that the break for breastfeeding are applied systematically. HR Manager was properly trained. When returning from maternity leave, female workers are entitled to 1 hour per day to breastfeed. A contentment form is signed as evidence of their will. 2 Assessment Feburary 2018 Feb-17 Compensation Overtime Wages Workers receive a 30 minutes lunch break although the internal work rules prescribe 1 hour.The remaining 30 minutes should be considered as overtime. Provide one hour break as indicated in the internal work rules. Lunch break time is being respected, factory posted some signage to let workers know about one hour break for lunch. Feb-17 Compensation Overtime Wages Night shift payment were not compensated at 100 percent above the normal wage. Pay night shift accordingly. Facility made all the necessary adjustment on the payroll in order to properly compensate overtime work at night shift. The correct payment can be verify upon the night shift re-opens. Feb-17 Compensation Paid Leave Payments for non-working holidays are based on the minimum wage instead of average earnings. Pay the legally mandated holiday on an average earnings. The payroll system has already been changed, so that the non-worked holidays are paid based on the average earnings.. 208 Feb-17 Compensation Paid Leave Payments for weekly rest days are based on the minimum wage instead of average earnings. Pay weekly rest day on an average earnings. The payroll system has already been changed, so that the non-worked holidays are paid based on the average earnings. Feb-17 Compensation Social Security and Other Benefits The contribution to ONA for Buildings 34 and 35 is calculated based on the minimum wage. Pay ONA accordingly for all workers that have been working at the factory for more than three months. The required employer contribution to ONA for the workers in the printing building has already been paid. Feb-17 Compensation Social Security and Other Benefits The contribution to ONA for Buildings 34 and 35 is calculated based on the minimum wage. Collect and forward workers' contribution to ONA The contribution to ONA for all Willbes factories is now being calculated using the base salary. And contribution is now being collected from workers in the printing building. Feb-17 Compensation Social Security and Other Benefits The factory is not registered with OFATMA for maternity and health insurance. Register with OFATMA for maternity and health insurance. Our company has initiated the registration process with OFATMA, by paying the Company's contribution for the month of July/2017. The factory started to pay OFATMA's deduction for the month of September 2017. Feb-17 Compensation Social Security and Other Benefits The factory is not registered with OFATMA for maternity and health insurance. Register with OFATMA for maternity and health insurance. Collect and forward workers' contributions to OFATMA. OFATMA Officials started to visit our company to explain to our employees the scope of the Health Insurance. The factory started to pay OFATMA' deduction for the month of September 2017. Feb-17 Contract and Human Resources Termination Two termination files unproperly documented. Ensure to properly document in workers' files any relevant information relating to their employment contract. Human Resources Manager has been warned and retrained to perform his duties properly going forward. Periodical reviews are being conducted to make sure this does not happen in the future. 209 Feb-17 Contract and Human Resources Termination MAST notification is missing prior to the temporary suspension of work at the printing building in 2017. Send a notification to Ministry of Labor to justify the temporary suspension of work. The Print Shop manager He has been explained and trained already. Temporary suspensions will be notified to the Labor Office when reducing the workforce. Feb-17 Contract and Human Resources Dialogue, Discipline and Disputes Inadequate language from line supervisors. Add supervisory skill training for supervisors. Establish disciplinary measures for persistent offenders. Management informed the supervisors of possible sanctions for verbal abuse. Supervisors from all Willbes Haiti factories received the training on supervisory skills. Feb-17 Occupational Safety and Health OSH Management Systems The employer does not submit the records to OFATMA on a monthly basis. The factory submits the Submit to OFATMA on a monthly basis records on work- accidents report every related accidents and month. diseases. Feb-17 Occupational Safety and Health Chemicals and Hazardous Substances Two unidentified propane and gas tanks in the printing building. Identify all dangerous substances. Post warning near the gas tanks. Store properly any source of ignition. The gas tank have warning signs. Identification is placed. Feb-17 Occupational Safety and Health Chemicals and Hazardous Substances No MSDS' were available in the storage warehouse in the printing building. Ensure that MSDS' are available in the storage warehouse in the printing building. MSDS for all chemicals are available in the storage warehouse at the Print Shop. Feb-17 Occupational Safety and Health Worker Protection All of the single needle machines were missing finger guards. Ensure that machines have their necessary guards. Train the maintenance team on Occupational safety and Health issues. All single needle machines were provided with finger guards. Sewing machine operators will be trained on the mandatory use of them as to comply with our internal rules. Feb-17 Occupational Safety and Health Worker Protection 1 electrical panel in Building 34 was blocked by cardboard boxes. Ensure to keep electrical equipment away from flammable material. Have a weekly inspection tour to address punctual issues. This issue was corrected during the factory assessment and employees working on that area were warned and re-trained to keep the electric panels free of obstacles. 210 Feb-17 Occupational Safety and Health Working Environment Temperature level exceeded 30 C in packing , quality , sewing and cutting sections Ensure to maintain the temperature to a maximum of 30 C in all sections. Building 35 is under repair. The factory has started the installation work of a cooling system. Feb-17 Occupational Safety and Health Working Environment Light levels were inadequate in cutting and packing sections. Ensure a minimum of 500 lux in packing and pressing sections. The factory did an inspection of electrical installations to replace non functioning lights. Feb-17 Occupational Safety and Health Welfare Facilities Insufficient number of toilets for women. Ensure to comply with the Haitian Law on the required number of toilets for men and women. The factory is committed to build more toilets. Feb-17 Occupational Safety and Health Welfare Facilities No soap in the toilets. Ensure that soap is available in the restroom for the workers. This issue was corrected during the factory assessment; janitorial employee & supervisor were warned to keep the toilets provided with hand soap at all times. Feb-17 Occupational Safety and Health Health Services and First Aid No medical checks were arranged for newly hired workers within the first three months of employment. Arrange a medical check for workers within their first three months. All mandatory medical checks for all Willbes factory workers have been scheduled already. The plan will take around 4 months. Additional checks are being requested to OFATMA as well.Also,the factory changed the doctor's contract to full-time and started with the medical checks. Feb-17 Occupational Safety and Health Health Services and First Aid No periodic medical checks were arranged for workers who have been exposed to work-related hazards. Arrange at least two medical check a year for workers who have been exposed to workrelated hazards All mandatory medical checks for all Willbes factory workers have been scheduled already. The plan will take around 4 months. Additional checks are being requested to OFATMA as well. Also,the factory changed the doctor's contract to full-time and started with the medical checks. 211 Feb-17 Occupational Safety and Health Health Services and First Aid Annual medical checks were not provided to workers. This was also confirmed by workers during interviews. Arrange, at least, one medical check a year for all the workers. All mandatory medical checks for all Willbes factory workers have been scheduled already. The plan will take around 4 months. Additional checks are being requested to OFATMA as well.Also,the factory changed the doctor's contract to full-time and started with the medical checks. Feb-17 Occupational Safety and Health Health Services and First Aid Insuffficient number of onsite medical staff. Comply with the Haitian law regarding the onsite medical staff. Facility has a new clinic on site. Feb-17 Occupational Safety and Health Emergency Preparedness The emergency escape routes in Building 35 have not been marked according to the new layout. Mark emergency escape routes accordingly to the new layout of the building. Ensure that the evacuation map is adapted to the new layout. The emergency escape routes in Building 35 were marked according to the newly arranged floor layout. Feb-17 Working Time Regular Hours Pregnant women employed at the factory are unaware of their right to take two additional breaks. Provide one hour break to workers. Ensure that pregnant women are aware of their additional breaks. Post messages of their additional breaks throughout the floor and in the clinic room. Pregnant women employed at the factory are aware of their rights to take two additional breaks of half hour each. Feb-17 Working Time Regular Hours Prior authorization was not obtained from the Department of Labor before working at night in the printing building . Ensure to obtain the authorization from the Department of Labor before using overtime. The authorization letter has been sent to the Labor Office. They sent it signed back to the factory without the stamp. After the audit, the factory resent the later to get the stamp. Feb-17 Working Time Overtime Excessive overtime for workers in the printing building. Ensure to not exceed the legal limits of overtime. The compliance team informed the production units of the legal limit of 80 hour by trimester. Workers in the printing building no longer work overtime. 212 Feb-17 Working Time Overtime Workers receive a 30 minutes lunch break although the internal work rules prescribe 1 hour.The remaining 30 minutes should be considered as overtime. Provide one hour break to workers accordingly to the internal rules. Factory reviewed the daily break time. The working hours are displayed in prominent areas around the factory. Training was provided to HR 213 BETTER WORK HAITI - 18TH SYNTHESIS REPORT As a partnership between the International Labor Organization and the International Finance Corporation, a member of the World Bank Group, Better Work brings together various groups - governments, global brands, plant owners, trade unions and workers - to improve Work in apparel industry and make the sector more competitive. CORE DONORS TO BETTER WORK Netherlands Ministry of Foreign Affairs Swiss State Secretariat for Economics Affairs Ministry of Foreign Affairs of Denmark The Government of Australia Represented by the Department of Foreign Affairs and Trade (DFAT) The US Department of Labor Funding is also provided by DFID, Government of France, Government of Canada, Irish Aid, GMAC, Royal Government of Cambodia and private sector donors,including The Walt Disney Company, Levi Strauss Foundation, Gap Inc. and FUNG (1937) Management Ltd