A Day in the Life: Social Compliance Auditor
Technical Specialist Corporate Social Responsibility (CSR) at Intertek UK - Athiya Khatri - shares insight of her role as a CSR Auditor & reveals examples of non-compliances.
22 September 2023
It's often thought auditing life must be so glamourous with constant travel, in and out of hotels and meeting new people. And whilst all this has its charm, there is a little more to it.
Waking up at the crack of dawn to beat the traffic and reach our destination before 9am becomes a habit if you keep repeating it. Driving alone, often in the dark, to what maybe an unknown place. Then ensuring we are bright eyed and ready to start auditing at 9am (or earlier if requested by the site).
We conduct a lot of one day one auditor audits, so it can be lonely. On occasion we get bigger audits where we work as part of a team but that's generally not the norm.
A one-day audit usually starts at 9am and finishes at 5pm. There are many things that can add layers of complexity to the audit, which in turn add delays and create pressure on the auditor. These can be things like wage records being stored at external accounts offices, or agencies delaying the release of worker documents.
What does a CSR audit involve?
There are several components:
- Opening meeting – we conduct an opening meeting to set out the agenda for the day, explain the purpose of the audit and answer any questions that the site may have. Its also a good opportunity to set expectations such as cut of times because we have so much to do in a day.
- Site Tour – the purpose of this is to check health, safety, and environment, to make sure that the site is meeting its legal obligations and what the work force isn't in harms way.
- Worker interviews – we conduct these to obtain information on what its like to work at the site, and to understand working conditions, and to ascertain if there are negative things going on.
- Health, Safety, and Environment document review – this is simply a check to ensure all legally required documents and checks are in place, this can be things like a fire risk assessment, waste transfer notes, or boiler inspection records.
- HR document review - this is a review of HR policies such as disciplinary, grievance, freedom of association, and Modern Slavery statement. Additionally, the employee handbook, worker contracts, right to work documents, collective bargaining agreements and opt outs are also reviewed. This allows to auditor to ensure that the site is meeting legal and ethical requirements.
- Payroll and Working hours review – this is a review of a minimum of 3 months' worth of payroll and working hours records. The auditor checks that workers are paid at least minimum wage, paid for all hours worked, there are no financial penalties, and that working hours meet legal and ethical requirements.
- CAP write up – This is when the auditor writes up the findings. this can take up to an hour depending on the complexity of the audit program and the amount of detail required.
- Closing meeting – here, the auditor presents and explains the findings. This is also an opportunity for the site to ask questions. We discuss expectation on closing and non-compliances and observations. And we praise the site for any good examples that we have found.
After the audit the auditor has 24 hours to write up the full audit report. This will include adding details on what evidence was reviewed, what was missing, the non-compliances, observations, good examples, excerpts of applicable laws and codes of conduct.
What's the most challenging element of the role?
It's hard work, long days, sometimes you can be away from home for an entire week, and sometimes we see some major breaches of human rights, this can affect us.
What are non-compliances in a CSR audit?
Some of the non-compliances, or breaches that colleagues and I have seen in the textile industry are:
- Underpayment of wages: In this particular case I was shown payslips and bank transfers to show that every Friday, each worker was paid minimum wage for the 40 hours that they worked. However, workers said that they were told you withdraw half of the money and pay it back to the business owner on the following Monday otherwise they would lose their jobs. This meant that in reality they were paid half of the legal wage per hour.
- Clocking in records: We have seen cases where clocking in records show that workers only work Monday to Friday. And then we have seen broken needle records which have shown broken needles collected during weekend. This has meant that we could not accept the working hours records as they were created specially for us.
- Furlough fraud: Site claimed workers were sent home during the pandemic with 80% of their wages paid. This was correctly verified during the review of bank transfers and clock/time records. However, when the auditor further checked the broken needle records, there were several instances of dates during the furlough period entered by the facility. Further investigation into the delivery records showed shipments were made during the period and a non-conformance was raised for breach of the terms of the Government Furlough Scheme
What inspires me to do my job?
When we find and report a non-compliance, it is promoting continuous improvement to a business, and we can bring about positive change to people's working lives and that's a wonderful fulfilling way of life.
For more information on our social compliance solutions visit https://www.intertek.com/assurance/supply-chain-social/
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