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“Analyzing the Compliance practice of With respect to Worldwide Responsible Accredited Production (WRAP)”
A Study On Clifton Textile & Apparels Ltd, Baizid Bostami, Chittagong.

(THIS INTERNSHIP REPORT IS SUBMITTED FOR THE PARTIAL FULFILLMENT OF THE DEGREE OF BACHELOR OF BUSINESS ADMINISTRATION WITH A MAJOR IN HRM)

Prepared By:

Abdullah Al Mamun

Matric No: R101195

Program : MBA
Semester : Autumn 2011

Internship Duration: 1st September, 2011 to 1st December, 2011

Submission Date: 11th June, 2011

Department of Business Administration

Faculty of Business Studies

International Islamic University Chittagong

“Analyzing the Compliance practice of With respect to Worldwide Responsible Accredited Production (WRAP)”
A Study On Clifton Textile & Apparels Ltd, Baizid Bostami, Chittagong.

(THIS INTERNSHIP REPORT IS SUBMITTED FOR THE PARTIAL FULFILLMENT OF THE DEGREE OF BACHELOR OF BUSINESS ADMINISTRATION WITH A MAJOR IN HRM)

Prepared By:

Abdullah Al Mamun

Matric No: R101195

Program : MBA
Semester : Autumn 2011

Supervised By:
Mr. Abdullah Ahsan Mamun
Lecturer, DBA, IIUC

Internship Duration: 1st September, 2011 to 1st December, 2011

Submission Date: 11th June, 2011

____________________
Signature of Supervisor

Department of Business Administration

Faculty of Business Studies

International Islamic University Chittagong

Letter of submission

Date: June 11th 2011

To
The Dean,
Department of Business Administration
International Islamic University Chittagong,

Subject: Prayer for accepting the internship report.

Sir,
It is a great pleasure and honor for me to submit my internship report. I have successfully finished my internship in Clifton Textiles & Apparels Ltd. I worked on “Social Compliance Issue Under HR Department.” 180, Baizid Bostami Road, Nasirabad I/A, Chittagong. On the basis of my study. I am submitting this report on the actual facts & finding of my work. I would like to inform you that I tried my best effort in gathering information and data for preparing this report. The preparation of this report has helped me to a great extent in findings out the relation of theoretical knowledge and practical experience. I would like to express my intense gratitude for your kind and cordial guidance on preparing this report in given time.

I, therefore, pray and hope that you would be kind enough to accept my Internship Report and oblige thereby.

Sincerely yours,

…………………………….
Omayna Parvin
Matric no: B 071271
Department of business Administration
International Islamic University Chittagong

Acknowledgement

Al-Hamdulillah, At the very out set, I would like to express my deep gratitude towards
Almighty Allah (SWT) for the successful completion of the internship In a renowned organization & enabled me to present this report & submit this in the department in time. At the very outset I extended my heartiest gratitude and admiration to my supervisor
Mr. Md. Abdullah Ahsan Mamun, Lecturer of Department of Business
Administration, International Islamic University Chittagong, for his sincere advice, guidance and valuable suggestion in preparing and presenting this report.

I am very much grateful to Mr M.R. Kibria Khasru, GM, Clifton Textiles & Apparels
Ltd, who has spent his valuable time for introducing me with various departments of the Factory & providing necessary information & documents relating to the study.

I am really indebted to some executives and officers of CTAL , namely ...........
Mr. S M Shahed Hossain, Sr. Manager, HR & Compliance, Mr. Abu Sayem Chy,
Personnel Officer, Mr. Hasib Ahmed, Executive, HR& Compliance, Mr. AKM
Nazmul Hossain, Executive, HR& Compliance, Sharmin Akter Chy, Asst. Manager, Welfare, Yasmin Akter, Welfare Officer, Lipi Das, Welfare Officer for their well behavior, cordial response, support, kind cooperation and inspiration.

Beside, I am thankful to all the staffs of the CTAL, for their valuable co-operation during the internship period.

Executive Summary

Clifton Textiles & Apparels Ltd. (CTAL) is a Private Limited Company incorporated under company Act. 1994. It is a manufacturing as well as profit motive organization. The Company’s aim is to earn profit by providing quality products to its Customers.

In this report it has emphasized on Compliance Practice with respect to WRAP
Principles in CTAL. The major objective of the study was to get an in depth idea and on hand experience about the Compliance Practice with respect to WRAP Principles in Bangladesh, particularly in CTAL.

In preparing this report the information was collected from Primary as well as from secondary source. The information collected from daily activities during my Internship and face-to-face conversation with the officers used as primary source. As a secondary the information was collected from various procedure & policy of the factory, Various Books and various web sites.

In the duration of the internship, some barriers had been faced like budgeted time for the internship, data insufficiency, poor research materials facilities etc.

This report is divided into five chapters. In the 1st chapter is discussed about the
Background of the study. In the 2nd chapter is discussed about the Overview of Clifton Textile & Apparal Ltd, here includes the background and details of CTAL, the mission of CTAL, vision of the CTAL. The 3rd chapter will be discussed about the Compliance and WRAP. The 4th chapter is about the compliance practice with WRAP
Principles in CTAL. And the final chapter is about findings and recommendation and conclusion. All-out effort is given to make this report a complete and comprehensive one. Hope this report is make all the topics dealt in this report clear to the reader. The company may also gain from this report. If so, the effort to prepare this report will be a successful one.

Table of Contents
|CHAPTER NAME |Page No. |
|Letter of Submission |I |
|Acknowledgement |II |
|Executive Summary |III |
| |Background of Study | |
| | | |
|Chapter: 1 | | |
| |1.1 Introduction | |
| |1.2 Objective of the Study | |
| |1.3 Methodology of the Study | |
| |1.4 Scopes And Limitation of the Study | |
| |General Information About RMG of Bangladesh | |
| | | |
| | | |
|Chapter: 2 | | |
| |2.1 Historical Background | |
| |2.2 Effects of RMG industry on Economy | |
| |2.3 Buyers of RMG Industry | |
| |2.4 Products of RMG Industry | |
| |2.5 Competitors of Bangladesh RMG Industry | |
| |An Overview of the Company | |
| | | |
| | | |
| | | |
|Chapter: 3 | | |
| |3.1 Background of the ADL | |
| |3.2 Objectives of ADL | |
| |3.3 ADL at a Glance | |
| |3.4 Corporate Motto | |
| |3.5 Corporate Mission of ADL | |
| |3.6 Corporate Vision of ADL | |
| |3.7 Organogram | |
| |Sources of Law, Rules and Regulations | |
|Chapter: 4 | | |
| |4.1 Preliminary | |
| |4.2 BEPZA Instruction 1 & 2, 1989 at a Glance | |
| | 4.2.1 Conditions of Service and Employment | |
| | 4.2.2 Maternity Benefit | |
| | 4.2.3 Welfare Measure | |
| | 4.2.4 Leave and Holiday | |
| | 4.2.5 Wages and Payment | |
| | 4.2.6 Worker’s Compensation for injury by Accident | |
| |4.3 Relevant Law of Bangladesh Labor Code, 2006 at a Glance | |
| | 4.3.1 Conditions of Service and Employment | |
| | 4.3.2 Maternity Benefit | |
| | 4.3.3 Health and Hygiene | |
| | 4.3.4 Safety | |
| | 4.3.5 Working Hours | |
| |Findings, Recommendations & Conclusion | |
|Chapter: 5 | | |
| |5.1 Findings of the Study | |
| |5.2 Recommendations | |
| |5.3 Conclusion | |
|Bibliography |V |

CHAPTER-1: INTRODUCTION
|1.1 |Introduction |

In today’s world academic education is not enough to enable a student to proceed with confidence and reach his/her goal without having experience with the outside and practical world. In order to have an idea and gain experience as a student of Bachelor of Business
Administration of International Islamic University of Chittagong have to undertake internship program at any organization.
This report on “Compliance practice of Clifton Textiles & Apparels Ltd. with respect to World- wide Responsible Accredited Product (WRAP)” is a collaborated outcome of the 12 weeks
(3months) short internship program at Clifton Textiles & Apparels Ltd. Baizid Branch. It is a partial but essential requirement of the Becholer of Business Administration (BBA) program.
Human resource management is the effective use of human resources in order to enhance organizational performance that means it deals with people internal satisfaction and motivation to have outmost performance for the benefit of organization, society and country. To minimize the conflict, harmonize the industrial relation and to serve the country is fulfilled by implementation of compliance practice with respect to WRAP Principles.
CLIFTON TEXTILES & APPARELS LTD (CTAL) can be good example for this purpose.

|1.2 |OBJECTIVE OF THE STUDY |

Specific Objective:

The specific objective of the study is to get an in depth idea and on hand experience about the compliance practice with respect to Worldwide Responsible Accredited Production (WRAP) in Bangladesh, particularly in CLIFTON TEXTILES & APPARELS LTD (CTAL).

Broad Objectives:
1. To have in-depth idea about the company.
2. To have a good knowledge about WRAP and its principles.
3. To analyze how far CTAL comply with these principles.
4. To find out lacking of CTAL, if any exist.
5. To find out recommendations with findings.
|1.3 |SCOPE OF THE STUDY |

I was assigned the topic on “Compliance practice with respect to WRAP ” – which is accepted by the both Clifton Textiles & Apparels Ltd. and International Islamic University Chittagong. At CTAL, Firstly I have tried to acquire knowledge and experiences about the overall activities of the factory and then gradually preceded one department to another for extensive knowledge. Then observing the WRAP practice in different departments in CTAL.

|1.4 |LIMITATIONS OF THE STUDY |

From the beginning to end, the study has been conducted with the intention of making it as a complete and truthful one. However, many problems appeared in the way of conducting the study. During the study, it was not possible to visit the whole area of operation of the factory and other information regarding the study has been considered.
The study considers following limitations: ▪ It should be certainly mentioned that the time constraints is that first limitation of the study. Only Three months is not sufficient for gather prefect knowledge on the vast area of Compliance practice with respect to WRAP. ▪ There was not a free entry for the intern students to all the information of the factory because of their strategic policy. In some cases, the branch officers could not be able to supply me topic related data because of their huge work load. ▪ This is the first professional report written by the author. Naturally there was a Lack of in-depth knowledge as well as analytical ability for writing such report. Moreover there was a shortage of corporate research culture in the factory.

|1.5 |METHODOLOGY OF THE STUDY |

I used some sources to make the report informative. Different types of work conducted by me to the data for making report. They are following by:

Theoretical Works:
Theoretical works had been done to develop the study and report work. Studying books, journals, magazines etc.

Primary Data:
Primary Data had been collected by working and observations in different departments in factory and interviewing workers and officials.

Secondary Data:
These data were collected from annual reports, brochures, manuals, articles and searching websites.

CHAPTER-2 : OVERVIEW OF COMPANY
|2.1 |BACKGROUND OF CTAL |

Clifton Textile & Apparels Ltd is a Private Limited Company which started its business in 2004 located in Baizid Bostami Road, Nasirabad I/A , Chittagong. The name of the company arose from the Clifton Group. This company is a member of BGMEA. This company has got WRAP certificate (Platinum). It is a 100% export oriented factory in Bangladesh.

|2.2 | CTAL AT A GLANCE |

|Company Name |CLIFTON TEXTILE & APPARELS LTD |
|Mailing Address |Clifton Group Corporate Office,4, Jubilee Road, Jiban Bima Bhaban (2nd Floor), Chittagong, Bangladesh. |
| |E-mail: jalal@cliftongroupbd.com, mohiuddin@ cliftongroupbd.com, admin@ cliftongroupbd.com |
|Factory Address |180, Baizid Bostami Road Nasirabad I/A, Chittagong, Bangladesh. E-mail: kasru@ cliftongroupbd.com, |
| |ctal_hrd@cliftongroupbd.com |
|Year of Establishment |May, 2004 |
|Ownership Type |Private Limited Company |
|BGMEA Membership No |3088, May, 2004 |
|Accreditation |WRAP Certified Platinum |
|Total Area |111, 000 sq/ft |
|Total Machineries |1215 |
|Total Employees |3350 |
|Total capacity of Production |2,30,000 dozen |
|(Monthly) | |
|Facilities |Cutting, Sewing, Finishing, Quality, Packing |
|Product items |Knit product -Sports bra / Casual bra / T-Shirt /A-Shirt/ Beach Wear / Under-garments / Sleep Wear / |
| |Top-Bottom Set. / Shelf Cami./Panty, Boxer./ Brief. |
|Business Markets | USA-80%, CANADA-10%, EU-10% |
|Major Customers |Wal-Mart, TARGET, KOHL’S, JC PENNY, HBI, SEARS, KMART, HUGO BOSS |
|Head Office Key Person |1. Md. M Kamal Uddin Chy.-Chairman 2. Md. M Jalal |
| |Uddin Chy.- Managing Director 3. Md. M Mohiuddin Chy. –Director |
|Factory Key Person |1. Mr Kibria Khasru –GM – Factory 2. Shahed Hossain |
| |–Sr. Manager (HR & Compliance) 3. Mominul Hoque –Manager (Factory) |

|2.3 |OBJECTIVES OF CTAL |

The management fixes renewed objectives for every year to achieve: 1. Further reduction of rejection of garments by orientation on production process and monitoring from A to Z in the process as well as QC to make it most minimum ultimately. 2. More assurance of perfect fabric & accessories supply through strict monitoring of the suppliers. 3. Reducing alteration % further. 4. Reducing migration % of workers and increase employees’ satisfaction. 5. Every supplier must achieve best satisfaction on management of Clifton Textile & Apparels Ltd during the yearly re-evaluation process. 6. Increasing Customer Satisfaction by further. 7. Introducing at least two new buyers to ensure maximum market share of Clifton Textile & Apparels Ltd with in every 6 months. 8. Reducing breakdown % of all the machineries further. 9. Reducing Machine Maintenance timing by further.
10. Ensuring timely delivery of each order by meeting production target.
11. Increasing competency level of the company to further extent further for each of the employees working in Clifton Textile & Apparels Ltd by providing necessary training.
|2.4 |CORPORATE MOTTO |

“WILL NOT REST
UNTIL
WE ARE THE BEST”

|2.5 |CORPORATE MISSION OF CTAL |

CTAL started its operation with a mission to raise its corporate reputation to a level both in size fairly to attract the reputed buyers and attain the confidence so that bond between the company and the buyer is cordial and lasting. Result of company’s mission is achieved to great extent and evidenced by the fact that they have become a trusted supplier for largest apparel retailer Wall-Mart Inc. Around 3350 workers are working in this factory with 1215 machineries.
CTAL has still much way to go. To make the factory well equipped with the need of future and work place more comfortable for the people working inside.
The company has a number of development plans: 1. Floor extension on roof top to create more spacious and healthier working place. 2. New building for better office facilities and expanded modem medical facilities with Child Care Room. 3. Comfortable and separate arrangements for buyer inspection. 4. Establishment of ERP Solution 5. Company’s own Design Development Center

|2.6 |CORPORATE VISION OF CTAL |

CTAL is a 100% export oriented company producing wide range apparel items. As a visionary, the company is well structured for facing the challenge of “Quota Free” environment from 2005.From then, company still competing with other companies in the world. Because it is a company with the management input of a team of competent and committed professionals. As a result they remain competitive in the market; assuring customers’ satisfaction and reliability above all becoming true partners of the customers.
Company’s main strength is the human resource. Their vision is not only to supply quality product on time and economy but also understand the psyche of the customer in follow-up, interpersonal relation, information flow and response to customer.
Company’s vision is always forward looking to cope up with trend of apparel trade and the existing and new buyers. As a visionary the company started its operation with a well thought policy and took up mission to materialize the same. 1. Focusing on quality zealously is one of the basic needs to build strong buyer relationship with confidence based on understanding of buyer needs, communicating effectively and delivery of quality products according to the requirement and satisfaction of the buyers. 2. The companies’ quality policy also emphasize on safe and positive working environment of all employees. The management of the company is committed to improve the quality as continuous process in product, environment as well as satisfaction among the people behind the machine and the establishment. 3. In this respect company is very conscious and very strict in Compliance to local laws and buyer standard. Beyond the adherence of law and buyer standard the company give importance to common welfare activities and keep the employees in good mood. 4. Quality assurance is ongoing coordinated process: starting from fabric inspection to quality checking during every stage of production through packing and on time shipment.

|2.7 |ORGANOGRAM |

CHAPTER-3 : ABOUT COMPLIANCE & WRAP
|3.1 |CONCEPT OF COMPLIANCE |

Core definition: Compliance is undertaking activities or establishing practices or policies in accordance with the requirements or expectations of an external authority.
Explanatory context:
Compliance may be the result of legal mandate, policy statement, code of practice, guidelines, procedural manual or stated (institutional, organizational or personal) preferences. Compliance is usually a concession to an external authority, where external may be external to the group complying, without it being external to the institution (i.e., a teaching team may comply with university requirements). Although compliance usually means compliance to an authority of some kind, compliance can be to an internally, communally-agreed process or practice.
Analytical review:
The University of Mississippi (2004) states:
A compliance program has been described as a commitment by an organization’s top management to ensure that the organization plays by the rules. Compliance, in its simplest form, is the act of meeting the expectations of others. In health care, it means meeting the expectations of those who regulate our business, pay our claims, and grant us money. Compliance means abiding by applicable legal requirements, including deterring and detecting violations of the law.
University of Melbourne (2004) in answer to the question ‘What is Compliance’, states: Compliance is what we do to ensure that we meet the requirements of the law relating to our

activities. The University has an obligation to its staff, students and to the community to ensure

compliance with the law. Failure to comply with the law can have serious consequences for

people, the environment and the University, either through injury, physical or financial damage,

or though damage to our reputation. In addition to the University’s duties under the common

law, there are hundreds of statutes and regulations that govern its activities. Therefore, the best

approach to compliance is to take a proactive stance in meeting our legal obligations on a day-to-

day basis.

An example of internal enforcement of quality compliance is Nottingham University’s (2004) statement: Where policies are made clear in the Quality Manual, the University's Teaching Committee,

which is a sub-committee of Senate, has resolved that all Schools must adhere to them. It is the

Head of School's responsibility to keep his/her School's practice under review, and in line with

the Quality Manual. Compliance with the Quality Manual is checked by the University

Quality Audit teams.

Quality and compliance
At the simplest level, quality evaluation has encouraged, or even forced, compliance in the production of information, be it statistical data, prospectuses, or course documents. Such compliance means that taken-for-granted practices and procedures have had to be confronted and clearly documented. ‘It represents the minimum required shift from an entirely producer- oriented approach to higher education to one that acknowledges the rights of other stakeholders to minimum information and a degree of ‘service’. Quality evaluation is also a tool that can be used to ensure compliance at the local level, that is, within an institution. For example, quality assurance can be used to unify disparate institutions behind a common goal or framework. In the early days of the polytechnic sector in Finland, some Rektors used the Finnish Higher Education Evaluation Council’s (FINHEEC) pilot quality audits as a way to focus the attention of very diverse component institutions onto the new polytechnic mission and procedures. In Australia, the first external quality processes in the early 1990s under the auspices of the Committee for Quality Assurance in Higher Education (CQAHE) was used by the Vice-
Chancellor of Newcastle for internal purposes: From the point of view of the Vice-Chancellor of the time, the quality rounds represented an invaluable opportunity to attempt to change both culture and practice in an institution which had not previously set great value on the formal processes of quality assurance. The national quality assurance process therefore, was “harnessed and ridden” for all it was worth to assist the process of change management. (OECD/IMHE, undated) Quality evaluation is also linked to overt political agendas as well as to less overt ones, such as attempts to reduce the autonomy of academia and questioning the extent to which mass higher education is producing ‘work-ready’ graduates. Rather more controversially, quality evaluation has been accused of creating a smoke screen to ensure compliance to resource restrictions by covering the issues that arise when student numbers increase rapidly without a commensurate increase in staffing and resources. Indeed, a quality-management system can be viewed ‘from a
Foucauldian perspective as a method of controlling’. Control of academia is not via direct intervention, rather the state and the institutional management ‘maintain a degree of surveillance from a distance that ensures that the requirements of the system are met.

|3.2 |IMPORTANCE OF COMPLIANCE |

The importances of compliance in Apparel sector are following by:
1. To maintain quality in products.
2. To maintain quality in production process, systems and environment.
3. To maintain quality in raw materials.
4. To ensure better working environment for workers.
5. To provide better facilities for workers.
6. To ensure health and safety in factory.
7. To ensure security in the factory.

|3.3 |WRAP (Worldwide Responsible Accredited Production) |

Worldwide Responsible Accredited Production (WRAP) is a non profit organization dedicated to promoting ethical, humane, and lawful conditions and practices in manufacturing facilities all around the world. The WRAP certification program mainly focuses on the apparel, footwear and sewn products sectors and is expanding into all labor-intensive sectors, such as hotels, jewelry, furniture, construction and more.
The organization is charted to develop a series of codes and practices governing manufacturing conditions worldwide and is also tasked with licensing independent auditing firms to conduct audits based on those codes and practices. It is not a membership organization, and does not certify brands or businesses, only facilities.
In the interests of impartiality, WRAP's charter requires that a majority of its board members come from outside the apparel industry. Active support is provided by the International Apparel Federation and over 20 additional trade and industry associations.Over 1,700 factories from 60 countries have participated in WRAP certification alone in 2008. In 2009, WRAP gave its backing to the Tannery of the Year awards program that seeks to promote best practice in the tanning industry.

|3.4 |PRINCIPLES OF WRAP |

The objective of the WRAP Program is to independently monitor and certify compliance with the following standards, ensuring that a given factory produces sewn goods under lawful, humane, and ethical conditions. Note that it is not enough to subscribe to these principles;
WRAP monitors the factory for compliance with detailed practices and procedures implied by adherence to these standards.
The WRAP principles are following by:
|1. Compliance with Laws and Workplace Regulations: |
| Facilities will comply with laws and regulations in all locations where they conduct business. |
| |
|2. Prohibition of Forced Labor: |
| Facilities will not use involuntary or forced labor. |
| |
|3. Prohibition of Child Labor: |
| Facilities will not hire any employee under the age of 14 or under the minimum age established |
|By Law for employment, whichever is greater, or any employee whose employment would |
|interfere with compulsory schooling. |
| |
|4. Prohibition of Harassment or Abuse : |
|Facilities will provide a work environment free of supervisory or co-worker harassment or |
|abuse, and free of corporal punishment in any form. |
| |
|5. Compensation and Benefits |
|Facilities will pay at least the minimum total compensation required by local law, including |
|All mandated wages, allowances & benefits. |
| |
|6. Hours of Work: |
| Hours worked each day, and days worked each week, shall not exceed the limitations of the |
|country’s law. Facilities will provide at least one day off in every seven-day period, except |
|as required to meet urgent business needs. |
| |
|7. Prohibition of Discrimination: |
| Facilities will employ, pay, promote, and terminate workers on the basis of their ability to do |
|the job rather than on the basis of personal characteristics or beliefs. |
| |
|8. Health and Safety: |
| Facilities will provide a safe and healthy work environment. Where residential housing is |
|provided for workers, facilities will provide safe and healthy housing. |
| |
|9. Freedom of Association and Collective Bargaining: |
| Facilities will recognize and respect the right of employees to exercise their lawful rights of |
|free association and collective bargaining. |
| |
|10. Environment: |
| Facilities will comply with environmental rules, regulations and standards applicable to their |
|Operations and will observe environmentally conscious practices in all locations where they |
|operate. |
| |
|11. Customs Compliance: |
| Facilities will comply with applicable customs laws, and in particular, will establish and maintain |
|programs to comply with customs laws regarding illegal transshipment of finished products. |
| |
|12. Security: |
|Facilities will maintain facility security procedures to guard against the introduction of non |
|-manifested cargo into outbound shipments (i.e. drugs, explosives biohazards and /or other |
|contraband). |

|3.5 | WRAP CERTIFICATION |

WRAP’s certification main focus is on the apparel, footwear and sewn products sectors. Today
WRAP’s facility certification program is expanding further to include all labor-intensive sectors, such as hotels, jewelry, furniture, construction, food, home furnishing, cutlery, glassware, carpet
/rugs, lamps and more.
The WRAP Certification Program is based on 12 Principles focusing on local law and workplace regulations which encompass human resources management, health and safety, environmental practices and legal compliance including import/export and customs compliance and security standards. WRAP’s certification sets three-levels of certification compliance – platinum, gold and silver , which is valid for 6 months (Silver), 1 year (Gold) to 2 years (Platinum).
The purpose of this three-level approach is to award participating facilities with the appropriate level of recognition for their progress in achieving full compliance with the WRAP Production Principles over a period of time.
Platinum Certificate:
Awarded to a facility that has demonstrated full compliance with all WRAP principles for three consecutive years, and has successfully “passed” each audit with no corrective actions and have best practices in place beyond Level A. Facilities that meet these criteria will be issued a two-year certificate. The facility will be subject to an unannounced audit during its two-year certification. Facilities must maintain continuous certification to qualify for the “Platinum” certificate.

Gold Certificate:
A one-year certificate is awarded to a facility that has demonstrated full compliance with all WRAP principles during the first audit, or in subsequent audits. The one year certification begins from the date of issue of the certificate, not from the date of the audit. (The “Gold” certification is equal to WRAP’s current compliance certificate.)

Silver Certificate:
A six-month certificate will be issued to facilities that demonstrate substantial compliance with the WRAP principles, but have minor non-compliances in policies, procedures or training that need to be addressed. Facilities may not have any “red flag” non compliances such as child labor, egregious health & safety or environmental issues, prison labor, forced labor or involuntary labor, or harassment or abuse of employees. Facilities must demonstrate that employees are paid the legal minimum wage and any required overtime compensation.
|3.6 | WRAP CERTIFICATION PROCESS |

WRAP Certification Program is a five-step process:
| | |

Step 1- Application:
To apply for certification, a facility needs to send a completed application form and pay a subscription fee (US$1195) to WRAP. To apply for certification, click on the website’s “New Application” or “Renew Certification”(whichever is relevant to the facility in question).
Step 2- Self-assessment:
The facility needs to complete a self-assessment of its situation against WRAP’s standard with the help of the self-assessment handbook. The handbook is available in English, Spanish and Chinese. It explains WRAP’s principles and requirements. To become certified, a facility will have to adopt all the principles and prepare documentation that demonstrates compliance.
Following the self-assessment, the facility 90 days to notify WRAP that it is ready for monitoring and inspection.
Step 3- Monitoring:
The facility contacts a WRAP accredited monitoring body which will assess the facility’s
Compliance with the WRAP principles and requirements. The facility negotiates a fee with the accredited monitoring body and schedules the date of the audit. A facility has six months from the date of registration and payment of subscription fee to WRAP (Step 1, above) to have the monitoring body submit its final report and recommendations to the factory management copy to WRAP with a favorable mention with regards to compliance.
Step 4: Evaluation:
Following the submission of the monitoring report, WRAP staff may notify the facility that
It needs to correct certain procedures and / or have the monitor complete an additional inspection and report. The factory has 90 days to make the corrections before the monitoring body conducts its follow-up inspection. If the factory does not satisfactorily implement corrective actions within the original six-month grace period, it must renew its application and repay the registration fee in order to be considered for certification. At that time, WRAP staff may recommend to the Certification Board that the factory be certified.
Step 5: Certification:
The certification board (currently the Board of Directors of WRAP) studies the recommendation of the WRAP staff, reviews the monitor’s report, and votes to award or withhold certification.
During the one year certification period, all facilities, especially those that needed a second audit are subject to additional unannounced inspections.
|3.7 |WHY WRAP POLICY |

The Worldwide Responsible Accredited Production (WRAP) program is the world’s largest facility certification program mainly focused on the apparel, footwear and sewn products sectors.
Facilities receive a certification of six months to one year based on compliance with the 12
WRAP Principles.

The WRAP Principles are based on generally accepted international workplace standards, local laws and workplace regulations which encompass human resources management, health and safety, environmental practices, and legal compliance including import/export and customs compliance and security standards.

WRAP has adopted a management systems approach toward compliance which requires that senior management adopt the WRAP principles in writing, assign the necessary staff to ensure the required practices are implemented throughout the facility, and that an internal audit system is in place to ensure continuous compliance. Facilities must undergo a rigorous self-assessment and then be audited by an independent third-party monitoring company.

WRAP enjoys wide support from the global apparel industry but is at the same time independent of the industry. Active support is provided by the International Apparel Federation and more than 20 additional trade and industry associations from around the world.

WRAP certifies facilities, not brands or businesses. WRAP is a non-profit, non-governmental organization and has a Board of Directors that is independent of any industry group. It is not a membership organization. Over the years, WRAP’s comprehensive factory-based model helped it grow into the world’s largest certification program for the apparel industry - 1,850 factories from around 60 countries participated in the program and over 1,400 certificates were issued in
2009 alone. Today, WRAP’s facility certification program is expanding even further, moving beyond just apparel to include all labor-intensive sectors, such as hotels, jewelry, furniture, construction, food, home furnishing, cutlery, glassware, carpet / rugs, lamps and more.

CHAPTER-4 : COMPLIANCE PRACTICE WITH WRAP PRINCIPLES
|4.1 |PRACTICE OF WRAP PRINCIPLES IN CTAL |

Principle-1:
Compliance with Laws and Workplace Regulations:
Manufacturers of sewn products will comply with laws and regulations in all locations where they conduct business.
Practice of this principle in CTAL:
Policy:
CTAL Continuously updates itself and complies with local and national laws and regulations including workers & buyers requirements related to all workplace regulations and social laws including environmental regulations, customs laws and security.
General:
1. Updates the Policies and Procedures Manual for all changes in laws and regulations related to labor practices, factory conditions, and environmental and customs compliance.
2. Assigns a qualified person with responsibility for informing the facility management of changes to laws and regulations related to labor practices, factory conditions, and environmental and customs compliance.
3. Designates an employee with responsibility for incorporating changes to laws and regulations in Facility procedures.
Responsibility, authority and communication:
1. CTAL has signed an agreement with Advocate Mr. Asish Kumar Kasha (State & Law), an expert in labor laws and consultant who updates regarding laws and regulations and Mr. Shahnewaz Ahmed GM-Administration, DGM (Factory) and Manager-HR & Compliance takes care of understanding and implementation of any amendment or any new requirement in the local laws.
2. For environmental requirements GM (Admin) and Sr. Manager - HR & Compliance updates from Environmental Ministry.
3. For Customs related requirements DGM/Manager- Commercial updates from Customs.

4. HR & Compliance Department are responsible to communicate with other management regarding the rules and regulation change.
5. Sr. Manager HR & Compliance is responsible to keep copy of ➢ Factory License ➢ Building Approval Certificate ➢ Fire License ➢ Incorporate Certificates ➢ Trade License ➢ EPB Certificate ➢ ERC / IRC ➢ Bond License ➢ Employee Insurance ➢ Group Insurance ➢ TIN ➢ BGMEA Membership Certificate ➢ Floor Diagram

6. Commercial/Merchandising Manager coordinates with freight forwarding agency/shipping agency to seek the necessary information related to current applicable laws and practices which needs to be fulfilled either at the factory premises or at the port, laws and regulations related to lobar practices, factory conditions, and environmental and customs compliance.
Responsibility and authority:
Sr. Manager- HR & Compliance
Responsibilities:
1. Collect all necessary documentation/paper/gazette of local laws & regulations as well as international issues that are relevant.
2. Updates the Policies and Procedures Manual for all changes in laws and regulations related to labor practices, factory conditions including Health & Safety issues, environmental, customs and C-TPAT /Security compliance.
3. Inform & collect any changes to laws & regulations related practices, factory conditions including Health & Safety issues, environmental, customs and C-TPAT /Security compliance by the local government.
4. Make written procedures that outline how & regulations in facility manual & procedure by through staff circulars, training sessions, e-mail & notice.
5. Promptly incorporates changes to laws & regulations in facility manual & procedure through staff bulletins, training sessions, e-mail & notice.
Communication & Training:
a. Staff/workers are being communicated related Laws & regulations, EHS and all compliance issues through conducting Awareness/Training Program, Seminar, Meeting, displaying Circular on Notice Board and PA System etc.
b. Where required, Sr. Manager HR & Compliance will train the designated persons to ensure the compliance of updated laws. Training records are maintained in the form of training plan and records.
c. Sr. Manager HR & Compliance also provides the relevant training materials pertaining to the new or amended laws to concerned Personnel. Sr. Manager HR & Compliance is responsible to monitoring that.
d. In causes where the new or amended law has direct impact on the workers, they are informed about the requirement or change in company policies or procedures through displaying the company polices, procedures, new or amended local laws on notice board maintained near the main gate/working floor.
Referrence:
▪ Constitution of the Peoples Republic of Bangladesh ▪ Bangladesh Labor Law-2006 ▪ Act No. 42 of BLL-2006 ▪ Minimum Wages Ordinance 2006 ▪ SRO No.280 dated 22 October 2006 ▪ SRO No. 360/Law/2010 dated 31 October 2010 ▪ Boiler Act 1923 ▪ Boiler Rules 1928 ▪ The Customs Act 1969 ▪ Memo No. F/ILO/BGMEA/207/88/CIF&E dated April-09/2003

Principle-2:
Prohibition of Forced Labor: Manufacturers of sewn products will not use involuntary or forced labor-indentured, bonded or otherwise.
Practice of this principle in CTAL:
Policy:
a. CTAL does not use involuntary or forced labor indentured, bonded or otherwise nor does it support the use of forced or compulsory labor in any form including bonded, forced, and/or compulsory prison labor. b. CTAL Prohibits all relevant individuals from concerning employees in any way or unnecessarily limiting employees’ freedom of movement. c. The company does not require employees to submit originals of documents at the time of employment or during the period of his employment with the company.
General:
a. Maintains employment application and service contract, to include statement applicants are seeking employment voluntarily and are not under threat or any penalty and to be signed by each applicant. Application and service contract copies are maintained in the employee’s personnel file. b. Issues compensation directly to worker as mentioned in their contract, company makes sure that the correct payment is paid to the workers as agreed. c. Job description of Security staff has been defined, limiting security tasks to normal security matters such as the protection of property or personnel. d. At the time of hiring Compliance ensures that the employee signs no bond as a token for continued employment. e. Original documents are only asked from the employees for the verification of photocopies of documents and after verification, original documents are returned to the employees. f. During the time of employee’s interview, the potential candidate is briefed about the fact that he/she is under no compulsion to join the company and similarly he/she is free to disassociate with company as per his/her own free will at any given time but under compliance with the rules as agreed in the appointment letter. During the interview one interview form maintain for all worker. g. Security service agreements do not contain language or terminology that may imply the existence of forced, indentured or involuntary labor conditions. Job descriptions of our security employees limit their tasks to normal security matters such as protection of facility property or facility personnel. For more details please check security personnel job description. h. We issues wages directly to employees. i. No original document kept from any worker and employee. j. We do not use Prison Labor with regard to local, national law and industry standard. k. Training Record regarding understanding about force labor for Mid Management is available in training file. l. Sr. Manager HR & Compliance ensures that workers who are doing overtimes are under no pressure or threat from their Departmental Head for compulsory OT. m. In case where any company’s employee decides to leave the company Sr. Manager HR & Compliance asks about the reason (s) of leaving in order to make sure that he/she is not leaving under unlawful compulsion or threat. n. Manager-HR & Compliance and all departmental heads are responsible for communicating, deploying and monitoring the Practice of effectively prohibiting involuntary or forced labor. o. Manager-HR & Compliance trains all departmental heads on the CTAL Policies and procedures prohibiting involuntary or forced labor. p. Suggestion box & Complain is placed in the facility, if any employee wants to report any incident he/she can use the Suggestion box without mentioning his/her identity, the matter will be investigated and resolved by higher authority of the Company. Suggestion box are directly controlled by Top Management (Director/Managing Director). Suggestion box opens once in a week/Month in presence of Factory HR, WWC/PC representatives and Representative of Director/Managing Director jointly. q. Manager-HR & Compliance ensures continuous communication between workers and management through designated members of different committees & Sr. Manager HR & Compliance directly monitor regarding that; the issues related to the workers are communicated to the management for effective corrective and preventive measures.
Contractual Labor:
Factory will ensure and obtain the following while engaging a labor contractor for seasonal or temporary work. Contract: ▪ Worker are not bonded or forces to work ▪ Signed statement from workers that they are working at his or her will ▪ Workers are paid minimum wages as per the Bangladesh Labor law 2006 ▪ SRO No. 280 dated 22 October 2006. ▪ SRO No. 360-Law/2010 dated 31 October 2010. ▪ Workers are given time cards and ID card ▪ Draft agreement with sub contractor ▪ Contract workers are not below 18-years of age. ▪ We obtains an executed statement from all labor brokers/agents used by the facility Stating that the brokers/agents are not supplying labor that is involuntary or forced.
Responsibility and authority:
The Sr. Manager, HR & Compliance and Plant In-Charge is responsible for implementation of the principle.
Responsibilities:
a. Proper communication of company’s prohibition of forced labor policy to the respective supervisors and workers.
b. Organizing meetings and training programs to ensure that the policy is properly communicated and understood, the minutes of the meeting are then recorded and circulated to all the participants as per distribution record list.
Communication & Training: a. Where required, Managing Director will notify that to the top management and will take required step about that and Sr. Manager HR & Compliance is responsible to train the designated persons to ensure the compliance of updated laws. b. Training records are maintained in the form of training attendance.
Reference:
ILO Convention-29, Bangladesh Constitution Article-34, ILO Convention-105

Principle-3:
Prohibition of Child Labor: Manufactures will not hire any employee under the age of 14, or under compulsory schooling, or under the minimum established by law, whichever is greater.
Practice of this principle in CTAL:
Policy:
a. CTAL does not encourage employing any person below the age of 18 years in any of its departments.
b. CTAL does not support the use of Child Labor or under age workers, not does it allow any child or young workers to be employed in any of its suppliers.
c. CTAL will discontinue business relations with such suppliers who use Child Labor or continued to do so even after insistence by the company for remediation of child labor.
d. CTAL Declared a Recruitment policy which is attached as an attachment with the manual in local Language. There is clearly written that the Recruitment Team strongly monitors not to join any child labor in the factory.

General:
a. Documents of Age verification:
Department of HR & Compliance ensures that the following documents are maintained in all the personal files of staff and workers whether directly or indirectly employed. • Bio-Data • Application form • Joining Letter • Interview Appraisal Form. • Compensation & Wages Details • Leave Application • Nationality Certificate (Photo Copy) • Voter/ National ID Card (Photo Copy) Or, • Copy of Birth Registration Certificate • Copy of High School Certificate (if required) or, • Registered Doctor's Age/fitness Original Certificate
b. Verification of Documents authenticity:
At the time of hiring, for direct/indirect employment HR Personnel verifies the photocopies against their original documents.
c. Hiring process for permanent staff:
Hiring process for permanent employees (staff and workers) at CTAL comprises of the following steps :- • Submission of signed (mandatory) application (in native language) • Interview is taken by the Recruitment Team of the Factory. For suitability of the person in terms of skill, technical expertise and work experience. • Filling of employee's profile/Application by HR Personnel (if any worker is unable to do)
Review of necessary documents, e.g. Recruitment information details, Age verification certificate (mandatory), birth certificate, National/Voter ID, National Certificate, academic certificates (where applicable) and work experience certificate.

Policies & Procedures Regarding Hiring / Employment:

1. CTAL will comply with the Local and National labor laws applicable in case of employment and other related activities. We implement the following policies while hiring or recruiting employee.
2. The Company employ adult workers only, 18 years old & above as defined by the law of the land.
3. The Company does not use forced labor and extra work from any person under any intimidation or for which the worker has not offered voluntarily.
4. We provide an equal opportunity to all employees and follow a non-discriminatory policy in employing and related activities.
5. We hire employees through an employment committee headed by Plant In-charge as the representative of top management. The committee is neither influenced nor biased by the any influence from inside or outside.
6. Employment is to be provided based on his/her education, experience, demonstrated skills and abilities (Mandatory testing during hiring), supported proof of age/fitness certification, sound physical and mental health.
7. Job evaluation and performance is the sole criterion for Increment, promotion, reward, disciplinary actions.
8. The Company actively pursues to hire the best human resources available in the country for employment.
Following procedures are being followed while hiring an employee:
1. Advertisement for employment is being placed in a populous area or newspaper or in front of the factory where the management feels as proper place. The advertisement specifies the position and required experience and qualification of job. 2. Appropriate verbal or written or practical test is taken to select the eligibility of the candidate. 3. The following documents must be provided by the candidate at the time of employment:
a. Complete Bio Data with 2 copy of stamp size and 3 copies of passport photographs (Bio Data Form is provided by the company).

b. Nationality Certificate from City Corporation or Union Parishad Chairman or Voter/National ID Card. c. Age/Fitness verification certificate indicating 18yrs or above on the date of application. Persons who are medically unfit will be automatically disqualified. d. The prospective candidate will go through a physical and mental check up by a qualified practitioner/ Company's Doctor and job assurance will be subjected to positive results from the tests. (An Age/Fitness estimation form must be completed which provides by the company). e. Certificates of education and experience where applicable. f. Upon satisfying the criteria for the job a prospective employee is given an appointment letter as per company’s rules. g. From the date of joining of an employee, ID card is being issued. Employees are responsible for the safe keeping of their ID card and required to wear it through out their staying in the factory premises. This ID card shows the name, designation, section, joining date of the employees. h. The worker will provide their existing service book to HR Department, however if a service book is not available with the employee then one will be issued to the name of employee. i. If an employee is hired on an emergency basis then the above mentioned documents should be updated in his or her personal file not later than 7 days after the joining date. However, notice should be given that at least by appearance the employee is well over 18yrs on the date of joining.

Discouragement of Child Labor:

CTAL discourages for employment of child labor at all levels in the society. The facility follows the under mentioned steps to show its resentment: • Discontinuation of business with suppliers who fail to address child labor. • Immediate termination of contractor, if found employing child labor.

Day Care Center and Baby Sitting Service:
Employees especially mothers with children below 6 years of age are encouraged to bring their children to the factory. A well furnished Child Care Room with toys and other baby’s items are provided by the company in 2nd floor besides the Director's office. Well trained Baby Sitters are there to take care of the children. Proper facility is provided, so that Mothers can give breast feeding to their children in this area. One register khata is maintained in the Child Care Center and Baby Sitting Service.
Responsibility and authority:
The Sr. Manager HR & Compliance and Plant In-Charge is responsible for implementation of this principle.
Responsibilities:
Communicating, deploying and monitoring the above practices in the factory.
Communication & Training:
a. Where required Manager-HR & Compliance will train the designated persons to ensure the compliance of updated laws.
b. Training records are maintained in the form of training attendance.
Reference:
Bangladesh Labour Law-06: Chapter-1, Section 2 (63), Chapter -3, Section 34 (1), Chapter -3, Section 35, 44(1), ILO Convention 138, 182.
Principle-4:
Prohibition of Harassment & abuse:
Manufacturers of sewn products will provide a work environment free of harassment, abuse or corporal punishment in any form.
Practice of this principle in CTAL:
Policy:
a. CTAL does not engage or support the practice of Corporal punishment, mental or physical coercion and verbal abuse.
b. CTAL promotes work environment in which no form of harassment is used by its supervisory staff towards the workers particularly female.
c. CTAL discourages use of any form of verbalism or gestures regarding sexual harassment towards its female staff and workers.
d. All supervisors, Floor In-charges, Production managers have given a written undertaking regarding the harassment and abuse policy. A regular follow up regarding the harassment and abuse is done by HR & Compliance Personnel.
e. CTAL abides by and follows legal disciplinary laws and procedures when needs a disciplinary action due to misconduct of any worker arises. Under no circumstances, the concerned Manager or section In-charge will resort to using physical means to punish any worker.
General:
Events requiring Disciplinary Action: • Following events can form the basis of initiating disciplinary actions against all employees. ✓ Breaking the company's rules. ✓ Use of Abusive language and vulgar actions. ✓ Psychical punishment and mental concern. ✓ Sabotage to company property and product. ✓ Creating an environment of unlawfulness or unrest among the employees. ✓ Failure to follow company’s rules and regulations on regular basis. ✓ Disclosure of company’s proprietary information. ✓ Misbehaving with superiors and fellow workforce. ✓ Harassing fellow workforce particularly females. • In case if an employee is found to be involved in any event as identified above Sr. Manager HR & Compliance will do the counseling with the worker and try to identify the reasons which causes any disciplinary action by the worker and verbally instruct the worker to mend his/her ways. In case of complex problem, the problem will be resolved by Plant In-Charge through HR Department.

• On the other hand if any in-charge or supervisor is found to be involved harassing or abusing the workers, the Sr. Manager HR & Compliance will do the counseling and try to identify the reasons, which may cause any disciplinary action.

• CTAL is committed to comply with applicable health codes and to reasonably accommodating the preference of both smoking and nonsmoking employees. For reasons of safety, public relations and other concerns, use of tobacco in the workplace is prohibited. CTAL prohibits the unlawful manufacture, distribution, dispensing, possession or use of a contraband substance in the workplace. Disciplinary action will be taken against the violators of this policy.

• Sr. Manager HR & Compliance ensures the minimum wages as per local laws for all employees whether directly or indirectly employed.

• Suggestion box & Complain is placed in the facility, if any employee wants to report any incident he/she can use the Suggestion box without mentioning his/her identity, the matter will be investigated and resolved by higher authority of the Company. Suggestion box are directly controlled by Top Management (Director/Managing Director). Suggestion box opens once in a week/Month in presence of Factory HR, WWC/PC representatives and Representative of Director/Managing Director jointly.

• All Supervisors, APM, PM are well aware about the company’s harassment and abuse Policy.

• On harassment and abuse undertaking has been taken from all Supervisors, In- charges, APM, PM, QM and all Managers which are available in their Personal file. During the recruitment of new supervisors, they have to give undertaking on harassment and abuse policy.

Discouragement of Pregnancy Test:

CTAL Ensures that no pregnancy tests are conducted for ladies at the time of appointment.

Disciplinary Action: Disciplinary action is being taken in under the following ways:

|Willful disobedience to any reasonable order of superior |
|Theft, fraud or dishonesty |
|Taking or giving bribes |
|Habitual absence without leave or absence more than 10 days |
|Habitual late attendance |
|Habitual breach of any law or rule |
|Riotous or disorderly behavior or any act subversive of discipline |
|Habitual negligence or neglect of work, go slow method, illegal strike |
|Habitual breach of any rule of employment including conduct, discipline approved |
|by Chief Inspector. |
|Falsifying, Tempering with damage of record and or properties. |

Responsibility and authority:
Sr. Manager HR & Compliance is responsible for implementation of this policy.

Responsibilities:

a. Proper communication of company’s policy on harassment, abuse, corporal punishment and signing of affirmation statement acknowledging the understanding from the respective supervisors.
b. Organizing meetings and training programs to ensure that the policy is properly communicated and understood, the minutes of the meeting are then recorded and circulated to all the participants as per distribution record list.
c. In case of any incident is reported either through suggestion/complaint box or directly through workers, authority will immediately communicate the matter(s) to the top management for immediate rectification and necessary action.
d. Consideration situation Action taken through company’s grievance Procedure
Communication & Training :

a. Where required Sr. Manager HR & Compliance and Plant In-Charge will train the designated persons to ensure the compliance of updated laws.
b. Training records are maintained in the form of training attendance.
Reference:
Bangladesh Labour Law-2006 Section-332, ILO Convention , Bangladesh Constitution.

Principle-5:
Compensation and Benefits: Manufacturers of sewn products will pay at least the minimum total compensation required by local law, including all mandated wages, benefits and additional payments.
Practice of this principle in CTAL:
Policy:
a. CTAL pays at least the total minimum compensation required by local laws, including all mandated wages, allowances and benefits to its workers and staff.
b. CTAL Does not pay less than the minimum wage prescribed by the local law to unskilled workers. To other category of workers, wages paid will be in line with those prevailing in the industry at the time, which also provides some discretionary income.
c. CTAL Posts legal minimum wage rates, overtime rates, benefit policies, and additional payment information in the native language.
d. CTAL Calculate overtime rate as per the prescribed by local labor law.
General:
a. Under supervision of Accounts and HR Department ensure the compensation according to this policy.
b. Company makes sure that salaries of employees are not deducted as a matter of punishment imposed from any superior to subordinate.
c. Company reviews, if any complaint/objection is lodged / raised through suggestion memo and discusses the matter with management and resolves it on priority basis. • Salary: Company makes sure that all the salaries of permanent employees are in accordance with the labor law and disbursed through an adequate procedure on given schedule.
|Grade |Salary (Tk) |House Rent (Tk) |Medical Allowance (Tk) |Total (Tk) |
|1 |6500.00 |2600.00 |200.00 |9300.00 |
|2 |5000.00 |2000.00 |200.00 |7200.00 |
|3 |2870.00 |1148.00 |200.00 |4218.00 |
|4 |2615.00 |1046.10 |200.00 |3861.00 |
|5 |2395.00 |958.00 |200.00 |3553.00 |
|6 |2230.00 |892.00 |200.00 |3322.00 |
|7 |2000.00 |800.00 |200.00 |3000.00 |

Paydays:
a. Salary will be paid within the 7(seven) working days of the month. Each salary will include earnings for all work performed through the end of the previous payroll period.
b. Overtime will be paid on same date of salary & Worker will sign in the 5 taka Revenue STAMP with date.
c. Organization provide Pay Slip to all worker to make them clear about the total payment and also if there is any absent deduction that is also mentioned in the pay slip. All worker are signing in the salary sheet (with attached 5 taka revenue STAMP)
d. In the event that a regularly scheduled payday falls on a day off such as a holiday, employees will be paid on the first day of work following the regularly scheduled payday in working time.
e. Salary of the workers includes all allowances as admissible under the law.
f. If a regular payday during an employee’s vacation, the employee may receive his or her earned wages before leaving for vacation if a written request is submitted at least one week prior to departing for vacation.
g. All workers are eligible to get attendance bonus for 100% attendance in each month. • Festival Bonus: A Permanent Employee who has completed 06(six) month continuous service from the date of the joining will be entitled to get festival bonus on an annual basis. Festival bonus is given twice a year on the occasion of Eid, equal to one month’s basic salary of the respective employee including 11 days festival leave with pay. • Production / Quality Incentive Bonus: A permanent employee who performs and demonstrates exemplary performance on production or quality related matters will be given a Production or Quality Incentive. • Dinning Facility: We provide well equipped canteen facility to our employees. The canteen area is located on inside the factory boundary. Totally capacity to accommodate is 1000 workers at a time. Dinning is well lighted and equipped with fire fighting equipments. Plates, glasses, spoons and safe drinking water is provided to the employees for their use. Company policy also displayed in Dinning Facility to create more awareness among all worker regarding the local labor law and company policy. • Drinking Water: Safe, healthy and clean drinking water is provided to the workers on every floor. This water is tested and treated on a regular basis to minimize the risk of employees exposed to water borne diseases. Company Testing Drinking water from authorized Government Organization in the interval of six month. Drinking water provided by Water Filter. Water Filter Checking system is in place. Proper documented records maintain to change, clean all water filter. All Drinking Water zone marked clearly for worker's easy access. • Free Medical: Company has own Doctors; visit factory all days in a week. One diploma nurse is available from 8am to 5 pm in each working day. • Group Life Insurance: Every permanent employee’s health and life is insured by a group life insurance policy free of cost. If an employee is injured or dies during his or her employment the employee will receive a compensatory amount from the insurance company.

• Service Book: Management providing service book for all permanent workers working in the factory. In the service book all details of the worker are included i.e. workers identity, address of the employer, details information of Job, salary structure, Leave register and disciplinary action etc. • ID Card: ID card issuance is an important policy of the company. In fact, we issue ID card to all employees. For newly joined worker, the company issues a temporary ID card which is being replaced by final ID card after receiving Code number from corporate office within the Month.
Responsibility and authority:
The Manager (HR & Compliance) and Plant In-Charge is responsible for implementation of this principle. Responsibilities:

• Proper communication of company’s policy on minimum wages, overtime compensation rates, legally mandated benefits and additional payments to all employees.

• Organizing meetings and training programs to ensure that the policy is properly communicated and understood, the minutes of the meetings are then recorded and circulated to all the participants as per distribution record list.
Communication & Training: • Where required, Sr. Manager HR & Compliance will train the designated persons to ensure the compliance of updated laws.

• Training records are maintained in the form of training attendance.
Reference:
Section 2 (45), 120, Section 121, Section 149, Section 108, Section 123, Section 126, Section 127, 128, Section 25, Section 19, Section 115, Section 116, Section 117, 117 (3), 117 (4), 117 (5), 117 (7), 117 (8), Section 118, 118 (3), Section 28, Section 264 (10), 264 (9), Section 26, 27, Section 23 (1), section 23 (3), 23 (2), Section 23 (4), Section 24, Section 45, 46, 47, 48 (1), 48

Principle-6:
Hours of works:
Manufacturers of Sewn Products will comply with hours worked each day, and days worked each week, shall not exceed the legal limitations of the countries in which sewn product is produced. Manufacturers of sewn product will provide at least one day off in every seven-day period, except as required to meet urgent business needs.
Practice of this principle in CTAL:
Policy:
a. CTAL informs all prospective employees, at the time of hiring, the policies and procedures and legal limitations on the maximum number of hours of work per day, week, and months, both regular and overtime, and the maximum number of consecutive days they can legally be required to work. b. CTAL ensures the hours worked each day and the days worked each week; do not exceed the legal maximum. c. CTAL provides one day off in every seven-day period. d. CTAL Implements a regular workday of 08 hours. e. CTAL has an organized system of record keeping. The time recording systems utilized and effective. f. CTAL defines the regular overtime requirements, as maximum-2 hours/day. g. Under no circumstances CTAL allows work over 6 days in a week and daily 2 (two) hours of overtime. h. CTAL allows employees legally required or contractually agreed rest breaks and identifies whether they are compensated. i. CTAL defines the normal workweek as 06 days from Saturday to Thursday and designates Friday as weekend or off day. j. Average Weekly working hour should not be more than 60 Hours. k. CTAL Designates days off for legal holidays as per gazettes holidays.
Normal Working Hours: • CTAL maintains the following working hours: • Saturday to Thursday: 08:00 am-7:00 pm. (including 2 hours overtime). • One hour break for lunch and rest/prayers. • Friday is general weekly holiday. • The Sr. Manager HR & Compliance and Plant In-Charge are responsible for ensuring all prospective employees are made aware at the time of hiring of legal limitations and the company expectations pertaining to hours of work and days of rest. • Sr. Manager HR & Compliance and Plant In-Charge ensures that under no circumstances, workers spend more than 8 working hours per day or 48 hours per week. • Every employee, when enters into factory premises, he/she uses swipe card.
All permanent employees of CTAL will be entitled to enjoy the following leaves: Casual Leave: 10 Days (With Full Salary) Sick Leave: 14 Days (With Full Salary) Earned Leave: 1 day for every 18 days of work (With Full Salary) Maternity Leave: 16 weeks (benefits provide as per Local Labor Law 2006)Applicable for women who is working minimum last 6 month Festival and Other Govt. Holidays: 11 Days (With Full Salary)
Earned Leave will be accounted for 1 year from the date of joining. Example: if any employee joined on 1st January, 2008 then on 31st December, 2009 will be counted as one year.
Festival leave will be calculated on a calendar year (January – December) basis. List of Festival Holidays is posted on the Notice Board.
Following policies will be applied or practiced & procedure will be followed to apply for the above mentioned leave: 1. An employee has to apply for leave in a prescribed form to apply for leave to the HR personnel 3 days prior to the proposed date of leave. The In-Charge/PM or Departmental Head will recommend the leave application and the HR Manager/ Factory Manager and Plant In-charge is the authority to approve the leave. 2. Approved leave application/form will be sent to the Personnel Department, where this approved application will finally be kept in the personal file of the respective employee. 3. For any emergency reason, if any employee remains absent must inform his/her In-Charge or departmental head or HR personnel for proceeding employee's leave and In-charge must hand over his/her duties & responsibilities to supervisor & co -workers to ensure that work is not hampered during their absence. 4. The management has the right to extend, modify, cancel, reduce, replace & make any changes of leave at their discretion. 5. 10 days Casual Leave with full pay is being granted to a permanent employee of the Company in a year. An employee cannot enjoy more than 3 days of Casual Leave at a time. Casual Leave cannot be carried forward to the next year or cannot be accumulated. If a casual leave is taken in between two government holidays or Friday then the casual leave for one day will be counted as two. 6. 14 days Sick Leave on full average wages is allowed per year. Employees falling sick must inform the Supervisor and Floor In charge by writing or other reasonable means of communication and must apply for medical leave on the date of joining. However, a medical fitness certificate or along with a prescription from a registered MBBS doctor must be required for absence due to medical ground leave more than 2 days. The factory appointed Doctor can also be contacted in this regard. Management reserves the right to verify, and upon information received may accept or reject the medical certificate. 7. Permanent Employee who has completed 1 year continuous service from the date of joining will be entitled to enjoy 1 day earned leave for every 18 working days worked by the employee. The Earn leave can be carried forward to the next year. However, the accumulated total cannot be more than 40 days. If it’s more than 40 days, then the employee either take the leave or take the equivalent cash amount. 8. Every pregnant woman employee is entitled to enjoy Maternity Leave in the following manner: a. Any female employee who has completed 6 months service is entitled for maternity leave. b. Maternity leave is granted with full pay for 8 weeks before and 8 weeks after the date of Expected delivery. c. A certificate from the Registered Physician or the Child’s Birth Certificate has to be submitted for eligibility of this leave. d. Any employee is entitled to 2 times maternity benefit during her tenure at the Company. But This facility is applicable for 2(two) children only in her life. It is done to encourage the Governments Family planning program. 9. Every employee of the Company is allowed at least 11 days Festival leave or other Holidays with full pay in a calendar year. The dates of festival holidays shall be fixed & conspicuously notified in the beginning of the year. This list of dates will be posted on the Notice Board of the Company. However, if factory remains open on a previously declared festival holiday due prior notice will be given and employees will be duly compensated both by pay and leave as per the provision of law.
Table of the Festival Leave
|Sr. No |Occasion |Date |Days |
| |Eidul Azha* | |3 days |
| |Eidul Fitar* | |3 days |
| |May Day |1st May |1 day |
| |Independent Day |26th March |1 day |
| |Victory Day |16th December |1 day |
| |International Mother Language Day |21st February |1 day |
| |Durga Puja* | |1 Day |

10. If any employee remains absent several times (4 to 5 times) without permission within 06(six) month which will be treated as Habitual Absence. 11. An employee remaining absent due to reasons that are unacceptable to the management will be treated as unauthorized absent. 12. A maximum of 10 days of unauthorized leave in a calendar year will be treated as habitual absence & unauthorized leave. 13. A joining notice (evidence available) is issued to an employee who remains absent without information for 3 consecutive days. 14. Factory Management initiates legal proceeding for 10 consecutive days above for an employee's unauthorized absence as described misconduct. Short Leave: • If in case of an employee wants to go for a short leave, he/she has to fill up the out pass and it must be approved by the FM/Manager-HR / Plant In-charge along with the recommendation of departmental head. • Approved out pass will be submitted to the Security personnel (Main Gate) before exit from the factory premises.
Compensation of overtime working:
Sr. Manager HR & Compliance & Plant In-charge make sure that overtime charges are paid at double rate of basic pay of the employee as prescribed by the law of land.
Willful Overtime by workers:
Manager-HR & Compliance & Plant In-charge strictly monitors the willingness of all those employees who usually do the overtime activity and without the will/wish of any employee does not engage him to be at overtime for any reason.

Working due to urgent business needs:

• CTAL does not allow over work more than legal limit of local law. But in regard of working due to urgent business needs, there is the provision for emergency work to full fill our valued Buyers. Factory also may be required to work on Holiday/Weekly off day due to any external or internal unplanned failure (like: Fire, earthquake, Bomb threat) which can stop the production. • Company has program to make awareness among all workers about any external or internal unplanned failure. Our security department is well trained and organized to face the such situation in emergency. • HR & Compliance Dept. and Plant In-charge make sure that in cases where the company operates on holidays / Friday, overtime charges are paid at double rate of basic wages and workers will be given the compensated holiday asserted by the law. • Sr. Manager HR & Compliance and Plant In-charge are responsible for communicating, deploying and monitoring the CTAL definition of “urgent business needs”.
Responsibility and authority: The Sr. Manager HR & Compliance & Plant In-charge are responsible for implementation of this principle.
Responsibilities:
a. The Sr. Manager HR & Compliance and all relevant individuals, including all individual responsible for the hiring process, on the CLIFTON TEXTILES & APPARALES LTD Requirement to ensure all prospective employees are made aware at the time of hiring of legal limitations and CLIFTON TEXTILES & APPARALES LTD Expectations pertaining to the maximum number of hours of work per day, week and month, and the maximum number of consecutive days the employees will be expected to work. The Facility documents the details of the training session, including date of session, names of individuals trained and the nature of the training content.

b. The Sr. Manager HR & Compliance trains all relevant individuals, including all individuals responsible for production coordination and scheduling, on the CLIFTON TEXTILES & APPARALES LTD .
c. The Sr. Manager HR & Compliance is responsible for posting the legal maximum regular and overtime hours and days of rest information in the native language (s) of the CLIFTON TEXTILES & APPARALES LTD Workers and management personnel.
d. Sr. Manager HR & Compliance and Plant In-charge is responsible for communicating, deploying and monitoring the Practice of ensuring all work is performed in the factory and employees do not work more that regular or overtime hours per day, week or month.
e. Sr. Manager HR & Compliance Train all relevant individuals, including all individuals responsible for procedures related to maximum number of regular and overtime hours, and required days of rest. The CLIFTON TEXTILES & APPARALES LTD Documents the details of the training session, including date of session, names of individuals trained and the nature of the training conducted.
Communication & Training:
a. Sr. Manager HR & Compliance will train the designated persons to ensure the compliance of updated laws.
b. Training records are maintained in the form of training attendance.
Reference:
Bangladesh Labor Law-2006,Section 41, Section 100, Section 102, Section 103, 104, Section 101, Section 109, ILO convention- 4, ILO convention- 14

Principle-7:
Prohibition of Discrimination: Manufacturers of sewn products will employ, pay, promote, and terminate workers on the basis of their ability to do the job, rather than on the basis of personal characteristics or beliefs.
Practice of this principle in CTAL:
Policy:
a. CTAL is an equal opportunity employer and believes in equal opportunity for all based on merit and ability to carry out the given responsibilities. It believes in equal pay for similar jobs and provision of equal opportunity to all employees to enable them to grow with the Company.
b. CTAL does not discriminate against anyone when hiring, promoting, pay, selecting people for training, at the time of termination of employment or retirement on the basis of religion, race, national origin, disability, gender, any association or political affiliation.
c. CTAL does not carry out any mandatory pregnancy test at the time of hiring of any female worker.
General:
Equal Opportunity Employer: • Equal employment opportunity applies to all aspects of employment practices including, recruiting, hiring, placement, promotion, demotion (if any), transfer, training, compensation, benefits and termination. Company ensures that all the employees whether employed directly or indirectly are employed solely on the basis of merit and no discrimination is made on the basis of race, religion and gender. • Company ensures that to the extent possible any vacant position is advertised either through newspaper or any other appropriate means (Banner, Circular and announcement the floor for their reference, if any) • In cases where any female seeks employment, Company ensures that she is not discouraged for employment due to fear of maternity leave or any other reason. • It is also ensured that female employees are not made to go through pregnancy testing. • In cases where the potential candidate is disabling but his/her disability cannot affect the nature of job for which he/she is seeking employment, the company does not discourage these employees and provide them equal opportunity to seek employment on merit. • Company ensures that in cases, where for the same type of job, male and female employees both are employed, they are hired on equal salary structure and company benefits and without any discrimination.
Reporting on Discriminatory Behavior: • In cases where an employee feels that he/she is treated with discriminatory behavior, he/she is encouraged to report such events to the Company. • Employer investigates the event or the employee’s complaint. • Where it is found that a severe incident of discrimination has taken place, Company records his observations and forward to Managing Director who decides due action. • Based on the objective evidences available and from the feedback of other worker as well as on the past discriminatory behavior, Managing Director may decide the following: -Terminate the worker -Demote him/her. -Retain him/her with last warning. • Results of investigation and actions decided will be filed in the personal file of particular employee. • Suggestion box is placed in the facility (Toilets), if any employee wants to report any incident he/she can use the facility without mentioning his/her identity, the matter will be investigated and resolved by the Company, after discussing the complaint with Production Manager.
Communication & training: • Where required, SR. MANAGER HR & COMPLIANCE will train the designated persons to ensure the compliance of updated laws. • Training records are maintained in the form of training attendance.
Reference:
ILO Convention 100 & 107, ILO Convention 111 & 19, Constitution Article 27 & 28, Bangladesh Labor Law 2006 section 345.
Principle-8:
Health and Safety:
Manufacturers of sewn products will provide a safe and healthy work environment. Where residential housing is provided for workers, manufacturers of sewn products will provide safe and healthy housing.
Practice of this principle in CTAL:
Policy:
a. CTAL utilizes all available resources to provide a Healthy and Safe working environment for all its workers and to eliminate all potential hazards that are capable of causing work related accidents.
b. CTAL through a systemized mechanism detects potential risk and hazards associated with the job or present in the work environment, which could cause harm/injury to the workers.
c. CTAL provides all necessary personal protective equipment’s and implements controls to ensure the safety of the workers and their health.
General:
1) To assist in providing a healthy and safe work environment for employees, customers and visitors, this is a top priority for CTAL.
2) Emergency response team is formed centrally combining Fire fighting team, Rescue Team & First aid team to induce workers to take active part in the work place safety programs.
3) The minutes of the EHS meetings are to be recorded and displayed on notice board.
4) Company makes sure that fire extinguishers are all available and all the employees are well trained to use these.
5) Company keeps fire-extinguishers location list in a file, which contains location identification number of fire extinguisher, refilling date and expiry date. This list is frequently updated as any Fire extinguisher is removed from the dedicated location either for refilling or due to any other reason.
6) Regular fire drills and training are conducted, involving every department on regular basis.
7) Provide potable drinking water, clean, safe and healthy work place. Maintaining water test at regular intervals, govt. inspection record for boiler and compressor with operators of such machine certificate.
8) Conduct sound level survey and light level survey regularly maintain records.
9) Provide clean and safe sanitation facility ensuring proper flashing for water, provision of soap and regular cleaning.
10) Identify and provide safe storing & handling of hazardous chemicals and maintain material safety data sheet (MSDS)
11) Sr. Manager HR & Compliance will ensure that all workers are provided with personal protective equipment, where necessary and provided basis training for usage of such equipment.
12) Sr. Manager HR & Compliance ensures through maintenance staff that needle guards, eye guards, pulley guards are properly installed on all the machines.
13) Doctor room & first aid boxes are provided to workers, in case of any injury, first aid is provided to employees by trained First Aid Members/Nurses.
14) All Toilets Cleanness regularly monitoring by management, Toilet Checklist record is available.
15) We Supplied sufficient and Request PPE (Personal and Protective Equipment) to every section, and we established a monitoring system. PPE Check list Record is available.
16) CTAL has all permanent employees completely insured a required under local laws.
17) Each employee is expected to obey safety rules and to exercise caution in all work activities.
18) Employees must immediately report any unsafe condition to the supervisor. Employees who violate safety standards, who cause hazardous or dangerous situations, or who fail to report or, where appropriate, remedy such situations, may be subject to disciplinary action, up to and including termination of employment.

Emergency Procedures: Emergency: It is defined as “Sudden happening demanding immediate action/response. For example, some of the emergency conditions may be due to the following:- - Fire/smoke - Bomb Blast/threat of Bomb Blast. - Accidental release/discharge of environmentally hazardous material. - Industrial accident. - All natural calamities as Earthquake, Tornado, Nonstop Rain etc. Response to Emergency: In case of emergency due to the above-mentioned conditions, the response of the factory personnel should be as per the following procedures. Action of Discoverer: A person who first detects any of the above mentioned conditions of emergency or any other “unusual” condition which can be assessed as the reason for emergency condition, first inform the area supervisor, informs the security guard, inform the emergency alarm responsible person to be ready for supervisor instruction. Action of the Supervisor: On information from the person or worker, supervisor shall inform the SR. MANAGER HR & COMPLIANCE, Security In-charge, Instruct and ensure that alarm goes on, if required. Ensure everyone of his area to proceed to the designated emergency assembly points. Actions of the Sr. Manager HR & Compliance: On information from the supervisor, Sr. Manager HR & Compliance inform the Head of ERFT, inform Fire brigade, assess the situation for the scope of emergency, coordinate between the supervisors for everyone in the factory to be gathered at the emergency assembly points. Actions of the ERFT Head: • On information from the Sr. Manager HR & Compliance or as the alarm goes on, the head of ERFT shall respond as per the emergency along with his team. • The Head of ERFT has a dedicated shelter (Assembly Point) known to everyone in the factory. • All the personnel are trained, instructed and provided with instructions that on hearing the alarm, they should immediately leave their work, switch off the machine (if working on a machine) and gather at the designated emergency assembly point. • All the departments are provided with respective evacuation plans. Emergency exits and paths to them are elaborately marked on the evacuation plans. Industrial accident: • In case of any accident, the discoverer informs the area supervisor immediately. • Supervisor access the situation. • Casualty is protected from the dangerous area and shifted to a safe place. • Supervisor informs the ERFT. If the accident is major one, supervisor instruct and insure that the emergency alarm goes on. • First Aid provided to the casualty. • If required the team leader arranges for external medical treatment. • Maintain accident / incident register. Fire Protection Equipment: • Portable and fixed fire protection equipments are provided for entire factory areas. It consists of fire extinguishers and fire buckets, which are available for use before the ERT arrives (Provided the associate has been trained in fire fighting operation). • The ERT is responsible for monthly inspection, maintenance and required record keeping of all portable fire extinguishers and fire trolleys. Any used or damaged extinguisher or trolleys should be reported to the ERFT leader. Fire Extinguishers (Portable): Properly marked 3 or 5 kg dry powder fire extinguishers are provided in ample quantity for all the production areas. Fire Buckets: Properly marked fire buckets are provided to all the main production areas or floor staircase. Emergency Light: The Safety & Health rule requires emergency lighting within facilities at the following areas: • Emergency lighting is installed in areas where exits would be hazardous during a power failure such as stairs and main departments. Exit Signs: Exit Signs are provided in specific locations in building to designate the means of exits from the building. • Must be installed at all required exit doorways and where necessary to indicate clearly the direction of exits. • Must be illuminated and also in local language.
Personal Preventive Equipment:
We use and provide the following personal protective equipments and training on how to use these, to our employees based on the nature of their work. These equipments are an essential for the employees and it is their responsibility to use them regularly and with care. If the protective equipment does function properly or does not fit concerned employee then the supervisor or the In charge must be contacted for replacement.
Goggles –are provided to employees who use the grinding, welding or lathe machine, especially the mechanics. A pair of goggles will be attached to such machines. This is to protect eyes from dangerous or harmful materials while working with these types of machines.
Hand Gloves– It is mandatory to use metal hand gloves for the employees working on the cutting machine. These metal gloves will reduce the risk of injury.
Mask – Should be used by all, especially for people working in the cutting and warehouse. However, masks should be checked regularly and if necessary changed to reduce irritation or uncomfortable.
Weight Lifting – It is a physical work and special care should be given while doing this type of work. Following procedures should be followed while lifting weight: a. Before lifting the weight refer to the tag of the fabric or object. b. Do not lean forward completely to lift the weight c. If it is a big object then use the help of another person, lift the weight from two sides up to waist high. Use as many people needed. d. Keep clear sight while carrying a load. e. Alert people around you while moving a load by making noise to avoid collision or hurting others. f. Try to use a trolley while moving a load from one place to another. Effort should be given to reduce as much as possible physical strength.
Wastage Disposal:
Our policy on wastage and disposal is not only related to material but also involves conservation of energy and use techniques to reduce misuse of utilities in the best possible way. 1. Our primary objective is to minimize waste in production process. We try and employ competent Manpower our train our employees to maximize our product. We implement more than adequate Quality measures at every production process to reduce quality rejects. 2. Source raw materials or packing materials from suppliers who use recyclable or environment friendly Products for use in production process. 3. Dispose waste through vendors who recycle wastage as applicable. 4. Ensure adequate measures to minimize use of natural resources and utilities like water, gas and electricity. 5. Take effective steps to ensure proper accumulation and documentation of generated and disposed waste and periodically review trends on regular basis.
The following procedures are followed to demonstrate our commitment to a healthy and safe work environment: a. Packing materials like cartons and poly bags are sourced from suppliers who use recycled paper and polyethylene. b. Every operation staring from storage, cutting, sewing, finishing through packing quality control processes are followed to ensure minimal wastage generation. c. Disposed or wasted cut pieces or popularly known as “Jute” are collected by floor cleaners by sweeping the floor every half an hour and collected in large bags and then removed from the floor and stored in a separate area. The vendors who supply these waste to recycling apparels collects these on regular basis. d. Employees are encouraged to keep their work area as much cleanly as possible. e. After production of each day machines, floors and related areas are cleaned by cleaners with appropriate materials. f. During lunch breaks or any intermediate breaks all lights, fans, machines are switched off by respective employees. Main switch for the floor is also turned off. If an employee takes a short break then he or she is supposed to switch off his or her machine. The Supervisors will ensure and encourage employees to follow this system. Cleanliness is next to godliness.

Following are cleanliness rules: i. Wash and dry hands before starting work. Especially after lunch this is a must. Soap should be used as required and care should be given not to waste. ii. Waste and garbage should be put away in specific place. iii. Toilets should be flushed and taps should be closed after use. Wash basins should also be cleaned after use. Cleaners will clean the toilet in regular intervals. However, employees should help, assist and cooperate in keeping the toilet clean and dry. If something is not working in the toilet then immediately inform the Supervisor. The supervisor will contact the Floor In charge and maintenance will take care of the problem. iv. Spit only in the designated spit box located on the stair case and while on the floor use the toilet wash basin. v. Lunches are usually provided in the canteen and use the canteen facility. vi. The canteen will open at 12:30 pm and is closed at 01:30 pm. & 01:00 pm and is closed at 2:00 pm. vii. Take own lunch and give space to others. viii. Do not damage canteen items like plate, glass, jug and spoon etc. ix. Do not put water and garbage in the canteen furniture and floor. Use bone plate and keep the table clean. x. Smoking is prohibited in the canteen. xi. Entry in Canteen is prohibited during unspecified time.
Disposal of Human Waste & Effluents:
As per section 54, Factory will take effective measured for removal of waste and effluent through using municipal sewerage system or by other means which are not open and a threat to health and hygiene or workers/ staffs.
Sanitary Waste:
Factory will place covered Bin in all female toilets for collection and disposal of sanitary waste in a hygiene manner on a daily basis. Containers to be washed with disinfectant.
Ventilation & temperature:
As per the section 52 we are providing adequate measures for ventilation and reduce temperature of the working floors and therein secure a reasonable condition of comfort to prevent injury to health. ➢ Adequate ventilation by placing windows and exhaust fans. ➢ Adequate installation of electric fans ➢ Insulation, Screening and ducting all heat generation pipes, machines in particular steam pipes, vacuum tables and boiler room.
Over Crowing: ➢ All Workers/Staff will be persuaded to use dust mask to prevent inhalation of dust created during manufacturing. ➢ Steam fumes created by boilers will be disposed off outside through pipes or in a manner not injurious to health. ➢ Chemical fumes created by spot-lifting guns discussed in hazards Chapter.
Over Crowding:
As per section 56 we arranged a minimum of 9.5 Cu. Meter per workers as a work station.
If the height of the roof is more than 4.25 meter, in that case 9.5 cubic meter is not required.
Lighting:
As per section 57 we are providing and maintaining sufficient and suitable lighting from natural source or artificial or both in all parts of the factory of healthy eye ➢ Light will not glare directly to the eyes of workers/ staff ➢ Shadows do not form and causes strain to the eyes of the workers/ staff. ➢ Windows will be kept clean for entering natural lights directly into working floors.
Drinking Water: CTAL are providing and maintaining sufficient supply of safe drinking water stations at a suitable point conveniently situated for all workers. • CTAL is providing safe drinking water stations in a ratio 1: 150 workers/Staff. • All Water Station is minimum 20 feet away from Latrines. • CTAL obtains safe and potable water certificate 6-monthly from relevant Government agencies. And a copy will be available near the water station. • CTAL is marking containers or drinking water station as “Drinkable Water” in Bangla. • CTAL is providing cups, glass, bottles to avoid transmitted diseases. • CTAL is ensuring regular cleaning of overhead tanks underground reservoir and containers in a hygiene manner. • CTAL is using halogen tablets or any other method and ensure drinking of safe and potable water. • CTAL is providing cold water for drinking of waters/staff during the summer. • CTAL are proving oral saline during summer season to prevent any de-hydration of workers/staff.
Responsibility and authority:
EHS (Environment, Health & Safety) committee is directed by HR & compliance team along with the cooperation of Plant In-charge and Medical Officers [Dr. Chowdhury Amir Md Faruq, Dr. M.N. Mustafa, Dr. Sharmin Sultana Dr. Shamima Akhter] who are responsible for health,
Safety & Environment requirement.
Responsibilities:
• Providing healthy and safe work environment to the workers. • Detecting potential risks and hazards associated with the job or present in the work environment, which could cause harm/injury to the workers. • Organizing meetings and training programs to ensure that the policy is properly communicated and understood, the minutes of the meeting are then recorded and circulated to all the participants as per distribution record list.
Communication & Training: • Where required, SR. MANAGER HR & COMPLIANCE will train the designated persons to ensure the compliance of updated laws. • Training records are maintained in the form of training attendance.
Reference:
Section 51, Section 52, OSHA standard, Section 53, Section 54, Section 55, Section 56, Section 57, Section 58, Section 59 & 60, Section 61, Section 62,
Principle-9:
Freedom of Association and collective bargaining:
Manufacturers of sewn products will recognize and respect the right of employees to exercise their lawful rights of free association and collective bargaining.
Practice of this principle in CTAL:
Policy:
a. CTAL recognizes and respects the rights of employees to exercise their lawful rights of free association and collective bargaining.
b. CTAL does not discriminate against employees who form or participate in lawful associations and/or collective bargaining. Forms of discrimination include, but are not limited to: - Wage penalties. - Suspension - Termination
c. CTAL does not illegally discriminate against employees who choose not to join any association or bargain collectively.
d. CTAL does not discriminate against applicants who have previously exercised their lawful rights of free association and/or collective bargaining.
General:
a. CTAL allows freedom of movement during employee breaks unless such movement interferes with the work of other employees.
b. CTAL Allow employees to leave the CTAL ground for reasons other than normal security reasons.
c. CTAL acknowledges the right of every employee to from free association or not to do so for collective bargaining.
d. In case if employees choose to form free association, they have to follow the legal procedure as laid down in the law for the formation of unions.
e. The employees can register themselves as the registered union. However if the other group of employees feels that they do not have the true representation in the registered union, they are free to form another registered union.
f. All the registered unions have to follow the following steps before putting any issue related to collective bargaining. • Nomination of union representative through selection or election process. • Development of Memorandum of Association. • Development of Charter of Demands.
g. If the need arises Production Manager is responsible to liaison between top management and employees and help formation of authorized body and to chalk down all the activities as per this procedure.
h. Two active committee is working in the factory where workers representatives regularly look after the interest of the workers. One is Workers Welfare Committee [WWC], and another one Participation Committee (PC). Both the committees have been formed in CTAL where members of committee were elected through hand raising election took place, nominated names were taken and supportive workers raised hand in favor of the nominee.
i. Members of work council are posted at strategic location in factory.
j. PC meetings will be held in every alternative month and meeting of WWC held in monthly basis, Chaired by top management and authorized Representative. Record of Minutes is maintained of the proceeding of the PC/WWC by the head of the Committee and minutes are communicated to top management.
k. Minutes of PC/WWC meeting are maintained and displayed at Notice Board.
l. Suggestion boxes are placed in the facility, if any employee wants to report any incident he/she can use the suggestion boxes without mentioning his/her identity. The managing Director and Director of the factory directly Monitor Complain & Suggestion Box if complainer thinks that any type of suggestion need to discuss in the WWC & PC then top management assigns to issue a notes regarding that to the Department of Admin, Plant In-charge, Sr. Manager HR & Compliance are responsible to discuss that in the WWC/PC meeting.
Responsibility and authority:
Sr. Manager HR & Compliance
Responsibilities:
Organizing meetings and training programs to ensure that the policy is properly communicated and understood, the minutes of the meeting are then recorded and circulated to all the participants as per distribution record list.
Responsibilities:
Organizing meetings and training programs to ensure that the policy is properly communicated and understood, the minutes of the meeting are then recorded and circulated to all the participants as per distribution record list.
Communication & Training: • Sr. Manager HR & Compliance will train the designated persons to ensure the compliance of updated laws. • Training records are maintained in the form of training attendance.
Reference:
BLL-2006-Section 2 (52), 2 (65), Chapter14-Section 209, Section 210, Section 211, Section 212 (1), Section 175, Section 2 (15), Section 176, Section 177, Section 179, Section 180, 196 (2), 298, Section 187, 192, 193, Section 190, Section 195, 196, Section 206, ILO convention 87
Principle-10:
Environment: Manufacturers of sewn products will comply with environmental rules, regulations and standards applicable to their operations, and will observe environmentally conscious practices in all locations where they operate.
Practice of this principle in CTAL:
Policy:
a. CTAL Complies with environmental rules, regulations and standards applicable to its processes and practices environmentally conscious practices in its work environment.
b. Where applicable CTAL performs initial environmental impact assessment and implements mitigation measures.

General:
Since the nature of production is mainly stitching with cut pieces of fabric as the main waste, the following industrial waste has been identified: - • Solid waste. • Water Waste
Initial Environmental Impact Assessment: • Seeks the updates from different buyer's related to environmental requirement for whom, CTAL is working. • Ensures the half yearly testing of drinking water compares the results against the requirement. • Where required, Sr. Manager HR & Compliance identifies the mitigation measures including use of PPE.
Mitigation Measures:
Based on the status of environmental performance mitigation measures are identified which can be: • Disposals of fabric waste and paper by CTAL to local vendors who use it as a material for re-cycling; • The water waste generated from utilities i.e. washrooms, water cooler, abolition area, and is discharge into sewerage system. • The workers use dust masks to in order to prevent the inhalation of fabric fluff generated from the fabric.
CTAL policy on wastage and disposal is not only related to material but also involves conservation of energy and use techniques to reduce misuse of utilities in the best possible way. 1. The primary objective is to minimize waste in production process. We try and employ competent manpower our train our employees to maximize our product. We implement more than adequate Quality measures at every production process to reduce quality rejects. 2. Source raw materials or packing materials from suppliers who use recyclable or environment friendly products for use in production process. 3. Dispose waste through vendors who recycle wastage as applicable. 4. Ensure adequate measures to minimize use of natural resources and utilities like water, gas and electricity. 5. Take effective steps to ensure proper accumulation and documentation of generated and disposed waste and periodically review trends on regular basis.
Responsibility and authority:
Sr. Manager HR & Compliance
Responsibilities:
EHSC (Environment, Health & Safety Committee) leading by SR. MANAGER HR & COMPLIANCE is responsible to implement the policy and ensure that the company complies with National Environmental Quality standards.
Communication & Training: • Where required Sr. Manager HR & Compliance will train the designated persons to ensure the compliance of updated laws. • Training records are maintained in the form of training attendance.
Principle-11:
Customs Compliance: Manufacturers of sewn products will comply with applicable customs laws and, in particular, will establish and maintain programs to comply with customs laws regarding illegal transshipment of sewn products.
Practice of this principle in CTAL:
Policy:
CTAL Complies with all applicable custom laws and in particular established and complies with laws regarding legal transshipments.
General:
• CTAL follows the below mentioned export process: - Receipt of orders. - L/C is received from buyer to open for import of raw materials. - Preparation of custom documents for import of raw materials. - Clearing the raw materials from customs. - Preparation of exports documents. - Negotiation. - Receipts of export proceeds. • Managers of Merchandising forward purchase orders for further processing. • Manager Merchandising does planning and evaluates the allocation of orders as per production plan and co-ordinates with the related personal to starts production according to purchase contract. • After completion of production the buyer’s QC or nominated agent conducts inspection. • Booking for export of the goods is given to shipping line by Commercial Department. • After final inspection, EXPORT form issued by concern bank and custom documents are prepared i.e. invoice, packing list and a set is forwarded to clearing and forwarding agent. • Clearing and forwarding agent prepares shipping bill and completes custom formalities and hand over the goods to shipping line or their agent with customs documents. The shipping line/agent release container for loading and left port for destination. • After sailing of vessel, shipping line issued B/L (Shipping Documents) and submits to negotiating bank along with Invoice, Packing list and others documents as per terms of contact L/C. • Receipts of exports proceeds. • Finally, follow up with bank for receipt of funds and on realization of proceeds file is closed.
Responsibility and authority:
DGM/Manager Commercial provides training regarding Customs Laws or any trade requirement and on amendments and maintain training records.
Responsibilities:
Related Documents: -Packing list. -Custom Invoice -EXP form -Original Letter of credit -Commercial Invoice -Bill of Exchange (Draft) -Bill of Lading -Certificate of Origin -GSP. Form “A” (Local Fabric) and ESP. Form (Imported Fabric) -Beneficiary Certificates. -Inspection Report.
Communication & Training:
Where required DGM & Manager Commercial will train the designated persons to ensure the compliance of updated laws. Training records are maintained in the form of training attendance.
Reference:
The Customs Act 1969

Principle-12:
Security: Manufacturers of sewn products will maintain security procedures at the facility to guard against the introduction of non-manifested cargo into outbound shipments (e.g. explosives, biohazards, and/or other contraband).
Practice of this principle in CTAL:
Policy:
• CTAL maintains vigilant security system to guard against the introduction of non-manifested cargo into outbound shipments. • CTAL supports all actions to discourage smuggling of goods and maintains a system to monitor the shipment loading process in the factory premises.
General:
The security system developed and implemented at CLIFTON TEXTILES & APPARALES LTD Consists of: - • PMAC (Personal Movement and Access Control): - The gatekeeper to the security room intercepts anyone who enters into the factory premises. - Security staff first inquires from the visitor, his name, category of visitor i.e. supplier, general visitor etc and whom he wants to see. - Security staff provides the visitor's card to visitor for his ready identification and put the information in the Visitors' register. - Host, security personal and the area supervisors ensures that the visitors should only visit the area for which they have been authorized to visit and are escorted by some company representative. - When the visitor leaves the factory premises then returns visitor card to the security staff. - Area supervisors of respective sections and security personnel ensure that employees” movement should remain confined in their respective areas and they should visit other sections only as a part of assigned job/ task. • Dedicated and Locked finished Goods area: - A separate finished goods area is maintained for the storage of packed cartons. (Packing area). A access register is maintained for any person without authorized packing worker. - The goods are moved into or from the area in the presence of security personnel. • Inspection of Container before and after loading: - Security Personnel inspects the container as per 10 point checking system in presence of Store In-charge/store Officer when it is docked for loading. The container is inspected for cleanliness, any unwanted item present in the container. - After the loading, Store In-charge/store Officer/security Personnel again inspects the container to identify any open carton, any unwanted item present in the container, physical condition of cargo after loading. - Inspection record of container for before loading and post loading is maintained. • Monitoring during loading: Store Officer/security personnel monitors the loading of shipment by ensuring the following : - Only authorized loaders stack the cargo - Loaders are not changed without his information. - Loaders do not stay inside the container for longer duration. - Any open carton is not loaded in the container. • Employees background check/verification: - At the time of hiring of security, Packing & loading workers/Staff background check of the potential employee is performed by Sr. Manager HR & Compliance and recorded in employees background verification form and kept in personal file of the employee. - To the extent possible, people whose background can’t be verified e.g. new immigrants in the country or city; they are not employed for the jobs related to security. • Weapons Ban: CTAL provides a safe environment for employees, volunteers, clients and the general public. Deadly weapons are prohibited in all corporation facilities. No one may enter any facility operated by CTAL while carrying a deadly weapon, concealed or otherwise. Employees who work in the field or perform other work outside of their workstation are prohibited from carrying weapons. • Physical Access Controls: Access controls prevent unauthorized entry to facilities; maintain control of employees and visitors, and protect company assets. Access controls must include the positive identification of all Employees, visitors and vendors at all points of entry. • Personnel Security: Processes must be in place to screen prospective employees and to periodically check current employees. Pre- employment verification, background checks, drug screening tests are to be performed. Companies must have procedures in place to remove identification, facility, and system access for terminated employees. • Procedural Security: Security measures must be in place to ensure the integrity and security of processes relevant to the transportation, handling, and storage of cargo in the supply chain. • Documentation Processing: Procedures must be in place to ensure that all information used in the clearing of merchandise/cargo, is legible, complete, accurate, and protected against the exchange, loss or introduction of erroneous information. Documentation control must include safeguarding computer access and information. • Security Training and Threat Awareness: A threat awareness program should be established and maintained by security personnel to recognize and foster awareness of the threat posed by terrorists at each point in the supply chain. Employees must be made aware of the procedures the company has in place to address a situation and how to report it. Additional training should be provided to employees in the shipping and receiving areas, as well as those receiving and opening mail. Additionally, specific training should be offered to assist employees in maintaining cargo integrity, recognizing internal conspiracies, and protecting access controls. These programs should offer incentives for active employee participation. • Fencing, Gates and Building structure: Perimeter fencing should enclose the areas around cargo handling and storage facilities. Interior fencing within a cargo handling structure should be used to segregate domestic, international, high value, and hazardous cargo. All fencing must be regularly inspected for integrity and damage. Gates through which vehicles and/or personnel enter or exit must be manned and/or monitored. The number of gates should be kept to the minimum necessary for proper access and safety. Buildings must be constructed of materials that resist unlawful entry. The integrity of structures must be maintained by periodic inspection and repair.
Responsibility and authority: Sr. Manager HR & Compliance
Responsibilities:
Manager Admin and HR is responsible to implement the policy on security to ensure that the company complies with the entire local/international laws and regulations.
Communication & Training: • Security I/C will train the designated persons to ensure the compliance of updated laws. • Training records are maintained in the form of training attendance.

CHAPTER-5 : FINDINGS,RECOMMENDATIONS AND CONCLUSION
|5.1 |FINDINGS |

During working in the factory I tried to find the compliance practice with WRAP
Principles in CTAL.
The findings are following by:
1.CTAL perfectly maintain compliance with Laws & Workplace Regulation.
2.CTAL perfectly maintain the Prohibition of Force Labor.
3. CTAL perfectly maintain the Prohibition of Child Labor.
4. In CTAL sometimes the Workers get abused by the Officers if any wrong happened in production process.
5. In CTAL, the salary scale for workers is not sufficient considering present living cost in Bangladesh.
6. CTAL maintains the compliance in Hours of work.
7. CTAL maintain compliance the prohibition of Discrimination.
8. There are some problems in Health & Safety. They are: • Workers do not do regular use of hand-gloves in cutting and eye-guard in sewing section.

• Drinking water provided for workers is not properly purified.

• There are five doctors, two compounder and two nurses for 3350 workers which is not sufficient to give proper medical treatment.

• The doctors are not well skilled that’s why in serious cases workers need to be sent to outside medical.

• The duty hour of Medical Service is till 7 p.m. which is not sufficient to provide regular service.

9. The authority strictly controls the movement of workers that’s why workers failed to

form any free association and collective bargaining.

10. CTAL maintains compliance in Environment.

11. CTAL perfectly maintains Customs Compliance.

12. The Transport facilities and schedule for female workers are not good because sometimes in

night they have to return to their home by their own effort. So there is security problem for female workers.

|5.2 |recommendations |

After finding some lacking of CTAL, I found some recommendations for CTAL which can solve

their problems and increase their performance.

The recommendations are following by:

1. The abusement to workers should be stopped and guiding them properly to improve their

skill in production process.

2. The salary scale should be adjusted with the gradual increase of living cost in

Bangladesh.

3. Workers should always do regular use of safety kits.

4. Drinking water provided in the factory should be 100% purified.

5. More medical staffs should be included by combining with the number of workers.

6. Doctors should be well skilled so that they can face any serious case.

7. Medical department should provide regular service.

8. The authority should allow the workers for free association and collective bargaining.

9. The transport facilities and schedule should be sufficient for female workers by

considering their security.

|5.3 |CONCLUSION |

Proper compliance practice with WRAP Principles in production system can contribute towards the development of that country’s economy. In Bangladesh, Textile sector has a leading power to the national revenue. Clifton Group Ltd. has introduced a new dimension in the field of innovative and benevolent compliance practice in our country. Keeping a side the pitfalls of the Clifton Group Ltd. has successfully made a positive contribution to the economy of Bangladesh with in very short period of time. I hope, Clifton Group Ltd. will do more work for social compliance development besides their business. To keep pace with ever-changing uncertain domestic business environment and face the challenges of revised global economic scenario, the Company should be more pro-active and responsive to introduce new compliant strategy to hold the strong position in home and abroad.

Bibliography:
Books:
➢ The Bangladesh Labor Code, 2006 (Third Edition) By Md. Abdul Halim & Masum Saifur Rahman. ➢ Constitution of Peoples Republic of Bangladesh

Publications: ➢ Annual Report of Clifton Textile & Apparels Limited ➢ Handouts and Booklets provided by Clifton Textile & Apparels Limited ➢ Articles of ILO Convention

Websites: ➢ http://www.cliftongroupbd.com ➢ http://en.wikipedia.org/wiki/Worldwide_Responsible_Accredited_Production ➢ http://www.wrapcompliance.org ➢ http://www.apparelsearch.com/names/W/WRAP_Worldwide_Responsible_Accredited_Production.htm ➢ http://cms.standardsmap.org/publish/itc_standards/worldwide_responsible_apparel_production

-----------------------
Disciplinary Action Procedure

Misconduct Criteria

Major Punishment:

- Removal - Dismissal a. if found guilty of misconduct under BLL-06 sec 24 . b. if convicted for any criminal offence. ref: BLL-06 sec 23(1))

Lightening Punishment: 1. Censure or Warning. 2. Maximum 07days Suspension without wages and subsistence allowance. 3. Fine. 4. With holding of Increment for period not exceeding one year. 5. Reduction to a lower post, grade or scale of pay for a period not exceeding one year 1.
Punishment Procedure(BLL-06 sec 24):
i. The allegations against him/her are recorded in written / Show cause ii. He/She is given a copy there off and not less than 7days time to explain. iii. He/She is given an opportunity of being hard. iv. He/She is found guilty after inquiry.
v. The employer or the manager approves of punishment order.

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