RBA VAP Standard V8.0.2

Responsible Business Alliance Advancing Sustainability Globally

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Table of Contents

1. Introduction
2. RBA Assessment Principles
3. VAP Definitions
4. Key Links to VAP Resources
5. Service Level and Quality Statement for VAP
6. VAP Program
7. VAP Process
8. Preparation for the Assessment
9. VAP On-site Process
10. Validated Assessment Report (VAR)
11. VAP Appeal and Guidance Mechanism
12. Corrective Action Plans
13. Closure Assessments
14. VAP Standard
15. References

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1. Introduction

1.1 Objective

This document is intended to serve as a guideline for deeper understanding of the Responsible Business Alliance Code of Conduct by offering elements to demonstrate Compliance to RBA Code for companies on their efforts to implement the RBA Code of Conduct on their operations. This guidance provides all the elements needed for a successful implementation for each element of the code of conduct.

The vision of the Responsible Business Alliance (RBA) is that through the application of environmental social and governance standards we can enhance the economic and environmental conditions of our members and their supply chains. This includes (but is not limited to) increased efficiency and productivity for companies and suppliers, improved conditions for workers economic development, and understanding and reducing risk to ensure continuity of supply.

The mission of the RBA is that Members, suppliers, and stakeholders collaborate to improve working and environmental conditions and business performance through leading standards and practices.

Fundamental to the RBA is the understanding that a business, in all its activities, must operate in full compliance with the laws, rules, and regulations of the countries in which it operates. The RBA encourages companies to go beyond legal compliance, drawing upon internationally recognized standards to advance social and environmental responsibility.

The RBA Code of Conduct (RBA Code) may be voluntarily adopted by any business in the electronics sector and subsequently applied by that business to its supply chain and subcontractors. To adopt the RBA Code and become a participant ("Participant"), a business shall declare its support for the RBA Code and seek to conform to the RBA Code and its standards in accordance with a management system as set forth in the Code.

For the RBA code to be successful, it is acknowledged that Participants should regard the RBA code as a total supply chain initiative. At a minimum, companies shall require their next tier suppliers to acknowledge and implement the RBA Code. The RBA is committed to obtaining regular input from stakeholders in the continued development and implementation of the RBA Code.

1.2 Document Format

Each element of the RBA code of conduct is presented in this document covering the following elements:

• Policy: The high-level minimum items and objectives that should be included in a policy and the goals the company is aiming to accomplish.
• Procedures & Practices: Refer to established methods and actions followed within an organization to ensure consistency and efficiency in various operational aspects.
• Controls & Monitoring: Refer to the processes and systems in place to oversee, regulate, and track activities, ensuring compliance with established standards and objectives.
• Records: Key information that should be created and retained.
• Leading Practices: Items which go beyond the current RBA Code requirements.
• Serious Conditions: Situations to ensure do not occur and/or are not present due to the high risk of adverse impact to rights holders.

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2. RBA Assessment Principles

2.1 Documentation

With regard to documenting a policy, procedures, control steps, or other documents, facilities do not need to have a separate policy or procedure for each item in this document. You can fit the noted items into your existing policy and procedure structure in a way that allows:

• Responsible staff (e.g., human resources, legal, EHS) to clearly understand what they are expected to execute, monitor, and control; as well as uphold themselves in an efficient and effective manner.
• Workers and suppliers to understand the expectations.

For instance, if the facility has a single labor policy document, it might be best to integrate the items from the RBA Code provisions in labor into that single labor policy.

2.2 Applicability

This standard applies to all in-scope workers in the facility and its supply chain, including any on-site suppliers and contractors.

In-Scope workers: direct (hired directly by the company) and indirect workers (hired through a labor agent or service provider) subject to an hourly increase or decrease due to volume production and/or covered by local laws governing overtime. Consistent with the RBA Validated Assessment Program (VAP) methodology focusing on production / hourly workers, the requirements outlined here are henceforth applicable to all workers excluding Professional Employees. Professional Employees are those engaged in work that is predominantly intellectual and varied in character as opposed to more routine mental, manual, mechanical, or physical work; such work involves the consistent exercise of discretion and judgment in its performance and is of such a character that the output produced, or the result accomplished cannot be standardized in relation to a given period of time.

2.3 "Stricter-of"

The RBA expectation is that companies are to follow the stricter of: local law, the RBA Code of conduct, or customer requirements (if applicable). Conversely the RBA does not expect a company to violate local law in order to comply with the RBA Code. Carefully consider and determine whether the law is truly requiring the facility to do something or rather it is allowing the facility to do something. A common example is a workers resignation notice period time. The RBA prohibits requiring in-scope workers (those covered by overtime law or impacted by production levels) from needing to provide and serve more than one month of resignation notice AND this must be documented in their employment agreement. Many countries have laws speaking to longer resignation notice timelines; however, these are typically there to cover situations where the worker was not provided with an employment agreement. In this case then the RBA Code is stricter, and workers should not be required to provide notice of resignation of more than one month in advance.

2.4 Policies Include Relevant Legal Provisions and Customer Requirements

It is not sufficient to verbally say that the facility follows a particular local law, regulation, statute, or customer requirement. Applicable laws, regulations, statutes, and customer requirements need to be integrated into company policy and procedure. For instance, if the minimum hiring age where one of your facilities is located is 16, then your company policy needs to note that the minimum hiring age is 16 (or higher if you choose or if required by your customers).

2.5 Adequate and Effective

Adequate shall mean appropriate and complete for its intended purpose. In practice, it means all required code compliance elements are included in the document (policy or procedure). For example, an adequate policy on prohibition of child labor includes all the elements RBA requires on this code topic.

Effective shall mean successfully achieves its intended goal or outcome. In practice, this means all implementation elements are deployed, and the outcome of process/procedure meets the RBA requirement. An effective procedure of child labor will include all RBA required implementation elements such as age verification, personnel files and no children are present or have been hired.

2.6 Small and Medium Sized Enterprises

For 250 people or smaller enterprises documentation may be less formal: fewer written directions and records. However, policies and procedures still need to be well understood and consistently followed by staff and workers.

2.7 Communication and Training

It is important that staff and workers responsible for implementing and conforming to any policies and procedures are aware of them. A communication and training plan, with periodic refreshing should occur.

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3. VAP Definitions

For a full list of RBA Definitions please check the document: RBA VAP Definitions

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4. Key Links to VAP Resources

• RBA Code of Conduct - https://www.responsiblebusiness.org/code-of-conduct/
• RBA Definition of Fees - https://www.responsiblebusiness.org/media/docs/RBADefinitionofFeesJan2021.pdf

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5. Service Level and Quality Statement for VAP

The RBA is committed to the improvement of conditions throughout the supply chains of its members. A key component of this commitment is a VAP assessment.

The following service and quality standards apply for RBA Validated Assessments (VA):

• A default independent, experienced, and approved fourth party provides quality management review of assessments.
• The program utilizes leading practices from different industry sectors.
• Assessments are performed by individually qualified assessors from reputable and approved assessment firms.
• The use of standardized RBA assessment protocols and templates.
• The APM provides ongoing guidance to assessors, members, reviewees, and their customers on the assessment program.
• The APM provides ongoing guidance to assessors and reviewees, during a live assessment regarding assessment specific questions. A live assessment is the period between the opening meeting of the on-site assessment and the closing meeting of the on-site assessment.
• The APM provides evaluation of RBA corrective action plan (CAP) for priority findings.
• Feedback mechanisms are available to address concerns about the performance of the VAP.
• Feedback on the assessment process and assessors is tracked, analyzed, and used to improve the performance of each assessment firm and to adjust the program, if needed.
• A fee-based Assessment Quality Management (AQM)-Managed corrective action plan service is available to help companies manage the CAP process for findings other than priority findings, i.e. Major, Minor and Risk of Non-conformance.

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6. VAP Program

The goal of the VAP is to measure and foster improvement in environmental social and governance performance and build capability within the supply base.

RBA assessments produce in-depth evaluations of the social, ethical, occupational health and safety and environmental performance of suppliers as measured against the assessment criteria. The assessment criteria are based on the stricter of local law, the RBA Code of conduct or customer requirements.

The VAP is part of an overall supplier engagement model: The process of assessing and improving labor, health and safety, environmental, and ethical practices in the supply chain. It is an assessment utilizing RBA Approved assessors, RBA developed assessments processes and protocols, as well as an RBA-vetted quality review by either the fourth party AQM or the RBA Quality Management.

The RBA VAP has been reviewed by legal counsel and is in line with US anti-trust and EU anti-competition regulation.

VAP Phases

Phase 1	Phase 2	Phase 3	Phase 4	Phase 5
Introduction	Assessment	Validation	Reporting	Sustaining
Initial risk assessment and code requirements	Facility risk self assessment questionnaire (SAQ) - upfront improvement	Validated Assessment process (VAP) Performance Improvement	Risk data and trend analysis	Innovation and leadership

Objectives of the VAP

• Encourage broad adoption of Environmental Social and Governance (ESG) leading practices by all companies and suppliers.
• Reinforce the RBA ESG expectations with companies and suppliers and ensure companies and suppliers are working toward conformance.
• Verify conformance with the RBA Assessment Criteria (AC).
• Identify opportunities for improvement in reviewee ESG practices, performance, and management systems.
• Provide companies with objective information to determine whether ESG expectations are being met at reviewed facilities.

6.1 Validated Assessment Report (VAR) Validity Period

A Validated Assessment Report (VAR) is valid for two years from the date of the initial assessment's closing meeting, unless a major change occurs within the reviewed site.

6.2 Roles and Responsibilities

There are different organizations and individuals who have responsibilities regarding the VAP.

6.2.1 RBA Staff

RBA Staff is responsible for VAP oversight, including:

• Providing guidance and direction to the Quality Manager (QM) and VA Program.
• Managing the RBA Code of Conduct review and revision process.
• Managing associated work groups, stakeholders, Member Companies, and others who have an interest in the VAP.
• Managing the finances associated with the VAP.
• Updating all program tools and documents.
• Providing and maintaining the data system that allows customers and suppliers to share RBA Validated assessment reports (VAR).
• Reporting program metrics and analysis to RBA and relevant RBA working groups.
• Developing appropriate training programs for VAP users and assessors.

6.2.2 Assessment Program Management (APM)

The Assessment Program Management (APM) is an RBA process which is responsible for coordinating VAP activities. These responsibilities include:

• Managing assessment firm contracts
• Managing assessment firm performance
• Approving assessment firms and assessors, including ensuring assessors have the required work experience, assessment skills, receive the proper training, and appropriate certification to conduct RBA assessments
• Maintain RBA approved firms and their assessor list
• Determining scope and duration for each VAP
• Tender and allocating VAs to assessment firms
• Providing assessment firms with relevant documents to facilitate VAP planning (if not in RBA-Online)
• Provide help desk support for live assessments
• Ensuring the end-to-end VAP timeline is followed
• Reporting all priority non-conformances identified during the assessment to Member Companies identified by the reviewee in attachment B (Attachment B Companies)
• Obtaining and reviewing feedback from reviewee management after a VAP
• Reviewing VAR to ensure quality and consistency globally with RBA criteria
• Managing a continuous improvement model that includes a closed-loop process incorporating feedback, driving improvement in the supply chain
• Implementing other VAP projects as necessary

6.2.3 Quality Management

Is a process and service responsible for coordinating VAP activities during a live assessment. These responsibilities include:

• Verifying that findings and ratings meet RBA criteria
• Managing guidance, issues, and escalations during a live assessment from assessors and reviewees during an assessment
• Coordinating VAR finalization with assessors and reviewees using RBA as an escalation point
• Reviewing and incorporating relevant reviewee feedback in the VAR
• Reviewing draft VARs, to ensure quality and consistency globally with RBA criteria
• Measuring assessors and assessment firm's performance, and consolidating this information with RBA senior management for review with the assessment firms
• Releasing the final VAR in RBA-Online
• Implementing other special projects as requested by RBA

6.2.4 Assessment Firms

Assessment firms ensure the VAP is conducted in accordance with the expectations defined in this manual. They communicate with the APM to increase the overall consistency and quality of VAP. Additionally, assessment firms must complete and submit assessment Reports on time.

Assessment firms must assign competent assessors who act in an ethical and responsible manner. Assessment firms must confirm that assessors conducting assessments have received the required training and have the proper experience to conduct assessments. All assessors must be on the RBA Approved assessor list.

Assessment firms must coordinate with the APM to schedule the VAP assessments.

For more information about assessment firm approval and requirements, see the RBA assessor Guidebook located at: http://www.responsiblebusiness.org/media/docs/RBAAuditorGuidebook.pdf

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7. VAP Process

7.1 Initial Assessments

7.1.1 Assessment Scheduling

7.1.1.1 Initial assessment can be scheduled at any time the reviewee is ready to do so. The time to schedule an assessment varies. Assessments may be scheduled up to 9 months in advance.

7.1.1.2 It is the reviewee's responsibility to begin the scheduling process through RBA Online. Refer to VAP request process for additional reference.

7.1.2 Assessor Selection

7.1.2.1 All assessment firms with expertise local to the reviewee are available for selection by the APM.

7.1.2.2 The APM selects the assessment firm, and the assessment firm assigns the assessors to conduct the VAP. The assessment Team must meet the requirements noted in the RBA assessor Guidebook.

7.1.2.3 Assessment assignments are determined by assessment firm performance. Performance measures include:

• Assessment firm quality (Accuracy, Professionalism, Timeliness)
• Availability
• Cost

7.1.2.4 For more information, contact the APM: vap@responsiblebusiness.org

7.2 Priority Closure Assessments

7.2.1 Assessment Scheduling

7.2.1.1 A priority and/or closure assessment(s) and/or CAP must occur within RBA specified time frames in this manual, to demonstrate closure of any findings identified in the initial assessment. For members these should be in accordance with the membership compliance guidelines.

7.2.1.2 Priority closure assessments are required if priority non-conformances are noted during the initial assessment. The scheduling process is started by the APM as the priority non-conformances are confirmed by the QM. Priority closure assessments are scheduled by the APM in accordance with the RBA VAP timelines.

7.2.1.3 Priority closure assessments utilize the assessment criteria and assessment protocol used in the initial assessment; exceptions require APM approval.

7.2.1.4 Steps to schedule a priority closure assessment:

• The AQM confirms the validity of priority finding and alerts the APM
• The APM initiates the priority closure assessment based on the VAP timelines for closure, soliciting assessors for the preferred assessment date

7.2.2 Assessor Selection

7.2.2.1 When priority closure assessments are required, if viable, the assessment firm which conducted the initial assessment will be assigned to conduct the priority closure assessment. Exceptions to this policy may arise when:

• The assessment firm is not available during the time window required to conduct the assessment.
• There are ethical issues, or potential ethical issues, with the assessor or assessment firm.
• There are extenuating circumstances, as determined by the APM, which require a different assessment firm (for example, a highly technical issue that requires an assessment firm with a specific skill set or knowledge base).

7.2.2.2 If a different assessment firm is needed to conduct a priority closure assessment than the assessment firm which conducted the initial assessment, the selection process follows the same selection process as for an initial assessment.

7.3 Closure Assessments

7.3.1 Assessment Scheduling

7.3.1.1 There is a three-month waiting period before a closure assessment can be conducted following the completion of the corrective action plan in the previous assessment.

7.3.1.2 If the closure assessment is requested after 18 months from the initial assessment, it is recommended to conduct an initial assessment rather than a closure assessment.

7.3.1.3 Closure assessments utilize the assessment criteria and assessment protocol used in the initial assessment.

7.3.1.4 It is the reviewee's responsibility to begin the scheduling process for closure assessments.

7.3.1.5 For more information, contact the APM: vap@responsiblebusiness.org

7.3.2 Assessor Selection

7.3.2.1 If the closure assessment occurs within 6 months of the initial assessment, if viable, the APM assigns the assessment firm which conducted the initial assessment to conduct the closure assessment. Exceptions to this policy may arise when:

• The assessment firm is not available during the time window required to conduct the assessment.
• There are ethical issues, or potential ethical issues, with the assessor or assessment firm.
• There are extenuating circumstances, as determined by the APM, which require a different assessment firm (for example, a highly technical issue that requires an assessment firm with a specific skill set or knowledge base).

7.3.2.2 If a different assessment firm is needed to conduct a priority closure assessment than the assessment firm which conducted the initial assessment, the selection process follows the same selection process as for an initial assessment.

7.3.2.3 If the closure assessment occurs after 6 months of the initial assessment, the assessor selection is the same as for initial assessments.

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8. Preparation for the Assessment

Assessments require preparation by the assessors and the reviewee. A successful assessment is an assessment which accurately reports the conformance performance of the reviewee to the RBA Code of Conduct. This requires an understanding of the VAP by both the assessor and reviewee.

8.1 Optional Reviewee Training

It is recommended that the reviewee who is new to the VAP process, or those that would like to learn more about the VAP attend an assessment preparation training class, helping them to learn about the assessment process, the RBA Code of Conduct, RBA expectations, and how to better prepare for the assessment.

Training Options:

• In person training events featuring our newly formed dedicated Training team: https://www.responsiblebusiness.org/training-events/code-vap-training/
• Factory Lead Certification Program: http://www.responsiblebusiness.org/resources/flcp/

8.2 RBA VAP Overview

8.2.1 The assessment is generally a multi-day event with multiple assessors. The exact number of person-days and number of assessors conducting the assessment is determined by the APM, based on the size, location, number of in-scope workers and scope of operations.

8.2.2 The assessment Criteria is based on the RBA Code of Conduct and local legal requirements. The criteria cover five main areas:

• Labor
• Health & Safety
• Environmental
• Ethics
• Supply Chain Management System

8.2.3 The assessment includes:

• Site observations
• Reviews of records, programs, procedures, and policies
• Interviews with management and workers

8.3 Assessment Scope

8.3.1 For VAP of a product supplier, the entire facility is 'in scope.' In scope means that all buildings and sections or areas are subject to the VAP. This includes, but is not limited to:

• All lines of business and all reviewee customer's production areas
• Production and supporting non-production areas (equipment rooms, wastewater treatment, maintenance shops, etc.)
• Common areas
• Office areas
• Storage areas (material warehouse, shipping and receiving, chemical and waste storage, etc.)
• Canteens and kitchens
• Dormitories, hostels, and any off-site housing of workers/migrant workers (if company or labor agent owns/rents accommodation for workers)
• Security room(s)
• Surrounding land within border of factory property

8.3.2 In Scope Workers Definition

A reviewee may request a reduced-scope VAP for any of the following reasons only however reviewees may choose to proceed with assessments where the below conditions exist without limiting the scope at their discretion:

• Site has more than 40,000 in-scope workers
• Operations at the site that are not within the industry of the facility being assessed
• Section(s) of the site are not accessible due to proprietary, or confidentiality reasons and written confirmation must come from the head office (management) of the Customers. However, workers working in these areas will be subjected to the workers interview as per the sampling methodology.
• Site has different companies operating within the same facility, which must include one or more of the following:
  • i. Operating under a different legal entity or license
  • ii. Having different management systems (including tracking of hours and pay) and management teams.
  • iii. More than 5 kilometers between facilities, if they are included in one assessment, then APM would include travel time at the scoping stage
  • iv. May not share employees (employees cannot go back and forth between companies without resigning from one company and being hired at the next)

To initiate a scope exemption, the reviewee or attachment B company must submit a written request to the APM during the assessment scoping.

8.4 Reviewee Preparation Requirements

8.4.1 Prior to the assessment, the reviewee must:

• Complete the RBA Facility Risk Assessment Questionnaire (SAQ).
• Confirm the assessment dates (start and end) with the assessment firm.
• Provide information on travel logistics, as requested, travel restrictions, and any other special considerations.
• Participate in the pre-assessment meeting (Subsection 9.5) and documentation review.
• Understand the on-site assessment agenda.
• Prepare and provide documents requested by the assessor, if any, prior to the assessment start date.
• Ensure that relevant information is available for the assessors when they arrive, including:
  • i. Names, phone numbers and locations of the reviewee's key people, as defined by the assessor
  • ii. Maps of the site and surrounding area
  • iii. Most current manuals, records and documentation required by the assessor
  • iv. Ensure that assessors will have access to all areas of the facility/facilities that are considered in scope for the assessment (e.g. dormitories, canteens, manufacturing, assembly, chemical storage areas, ...).
  • v. Ensure that working hours records and wage data are available.
  • vi. Invite appropriate staff members to the opening meeting, closing meetings, daily wrap-ups, and to accompany the assessors during the site inspection.
  • vii. Provide the assessors with meeting room(s), preferably with access to a telephone/internet line, printer and copy machine.

8.4.2 Prior to the assessment, the APM is available for additional guidance, if needed. During the live assessment, the Quality Manager is available for additional guidance.

8.4.3 During the live assessment the reviewee must:

• Populate the working-hours template after the assessors have selected the samples.
• Make appointments and set the interview schedule, as requested by the assessors.

8.5 Pre-assessment Meeting

8.5.1 After the assessment is assigned to an assessment firm, a pre-assessment meeting between the assessor and reviewee must take place.

8.5.2 For RBA assessments, the assessment firm is responsible for scheduling and conducting a pre-assessment meeting with reviewee management; this pre-assessment meeting should take place between 3 to 10 days prior to the assessment.

NOTE: If the reviewee has not been contacted by the assessment firm 3 days prior to the assessment contact RBA APM for assistance vap@responsiblebusiness.org

8.5.3 The following items should be addressed in the pre-assessment meeting:

• Assessor introduction
• APM approved assessment scope
• Assessment agenda
• Translation needs; mainly for worker interviews
• Travel requirements, if any, during the assessment (auxiliary or support buildings, different facilities, ...)
• Logistics, if needed (directions, preferred hotels and/or airports, travel restrictions and any special considerations)
• Site safety and security requirements
• Confirm exact time of arrival and time of opening meeting; ensure participation by the site manager and key staff
• Confirm there is an adequate area for performing the assessment, as well access to internet and phone (if needed)

8.5.4 Documentation preparation:

• Confirm the documents that will be needed and must be ready at the start of the assessment.
  • i. RBA Workforce composition survey
  • ii. Working Hours template
• Confirm whether there are any additional documents and records that are needed for the assessment team to prepare for the assessment (e.g. organizational chart, key staff members, on-site suppliers, ...)

8.5.5 For service provider assessments, the assessor shall contact both the management team at the reviewee location as well as the sites where the workers are deployed. Worker interviews and a facility tour should be arranged (where possible) at the sites where workers are deployed.

8.6 RBA Assessment Observer Guidance and Feedback

8.6.1 Observers to the assessment may be present during the assessment. This is to ensure quality and integrity of the process as well as provide improvement feedback on the performance of the assessment firms and assessors.

8.6.2 The role of the observer is to observe the assessment and to provide feedback on the assessment process and the assessors.

8.6.3 The observer must be from an attachment B company (RBA Member Company) and have social and/or environmental, VAP or assessing experience; the RBA may provide exceptions to these requirements.

8.6.4 Only 2 Internal observers and only 1 Attachment B company observer are allowed per assessment.

8.6.5 Only 1 assessment firm observer is allowed per assessment.

8.6.6 RBA reserves the right to remove any observer from a live assessment if the observer rules are not followed.

Observer Rules

8.6.7 The APM must be:

• Notified of the observer at least 2 weeks before the start of the assessment.
• Provided with the name of the observer, company, email address and mobile number.

8.6.8 The observer:

• May participate in the site observation in the following areas:
  • i. Common areas (e.g. canteen, dormitories, general staff areas, pollution control, etc.)
  • ii. Production areas specific to the observer's company
• May observe and participate in the document review but may only review documents that either apply to the reviewee as a whole or those related to their company's business with the reviewee.
• Will not interfere with the assessment in any way.
• Will not advise or influence the assessment firm regarding the findings, process, scoring, or other parts of the assessment.
• Will not advise, guide, or interfere with the management of reviewee.
• Will be introduced by the assessment firm as the observer in interactions with staff during the assessment.
• Will not participate in any formal interviews and may also be required not to participate in some or all informal interviews.
• Should attend all key on-site meetings, including the opening and closing meetings.

8.6.9 At the end of the assessment, the observer completes the observer Feedback Form and submits it to the APM.

8.6.10 The assessor keeps all information regarding workers, information learned from interviews, and all proprietary information confidential from the observer.

8.6.11 Exceptions to these guidelines may be given by the RBA.

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9. VAP On-site Process

The VAP must be conducted using the following process.

9.1 Assessment Start

9.1.1 Upon site arrival, the assessors will present identification.

9.1.2 The assessor(s) must bring with them all assessment tools and equipment necessary for the assessment.

9.2 Opening Meeting

9.2.1 All assessments begin with an opening meeting. The assessors must use the RBA assessment Opening Meeting Template as a foundation but can be modified as needed for the particular VAP situation.

9.2.2 Assessor Requirements

9.2.2.1 The assessor discusses the following topics in the opening meeting:

• Purpose and objectives of assessment
• Assessment schedule, scope, and approach
• Discussion of site observations, interviews, record reviews, taking field notes
• Discussion of representative sampling
• Introduction of assessment observers
• Preparation for daily wrap-ups and closing meeting including APM notifications of priority findings

9.2.2.2 The assessors should answer any questions the reviewee may have.

9.2.3 Reviewee Requirements

9.2.3.1 The reviewee should discuss the following in the opening meeting, if applicable:

• Visitor safety, security, and escort protocols
• ESG program and organizational assignment of responsibilities ESG accountabilities and organizational responsibilities
• ESG goals, performance, and current issues
• Business climate for the facility
• Review of facility operations
• Identification of notable site activities occurring during the time of the assessment including the seasonal changes of production load – high, moderate, and low months / seasons.
• Major changes since the last assessment
• Review of the pre-assessment documentation
• Interview schedules
• Identification and location of the assessor work room(s)
• Phone and internet protocol and support personnel
• Review of site work hours
• Other information relevant to the assessors and the assessment process

9.2.3.2 The reviewee is free to invite any reviewee site staff or employee to the opening.

9.2.4 Interviews

9.2.4.1 Worker interviews are a sensitive topic, and proper management of the interview process is an important element of the assessment.

9.2.4.2 There shall be no retaliation (e.g. reduction in pay or benefits, losing jobs, intimidation, or any other penalties) for any information discovered during an interview.

9.2.4.3 Throughout the assessment, the assessors interact with workers gathering information in both formal and informal situations. Formal interactions are when the assessors selects and interview certain in-scope workers individuals. Informal interactions occur as the assessors have brief interactions with workers at their place of work or in other areas of the factory (e.g. dormitories, canteens, common areas, parking area).

9.2.4.4 Formal interviews are conducted privately, without the presence of reviewee managers, other staff, or observers. The workers' identity and comments must remain confidential. Failure to do this will result in a penalty to the assessors' performance score and possibly a suspension depending on seriousness of the violation.

9.2.4.5 Formal interviews are conducted in two ways: individually or in group settings.

9.2.4.6 Formal individual interviews generally last about 10 minutes. Formal group interviews typically last about 20 minutes, but may take longer, if needed, at the assessor's discretion.

9.2.4.7 Interviewees should represent a range of workers including:

• Permanent and temporary
• Both direct hired and indirect hired production workers
• Direct hired non-production workers (security, cleaners, food preparation)
• Employees and subcontract labor
• New hires and experienced workers
• More and less skilled positions
• Various departments
• All shifts
• All genders
• All nationalities (limited to foreign workers who are not foreign expatriate or skilled staff)
• Worker representatives, if present
• Pregnant woman, nursing mothers, and workers with Disabilities if present

NOTE: Indirect hired non-production workers (security, cleaners, food preparation) are not included in the group interviews.

9.2.4.8 The assessor should immediately inform the APM if site management is unwilling to allow interviews, or if the assessors feel that workers talking openly with assessors will compromise the workers. The APM will assess the situation in order to determine if the assessment should continue.

9.2.5 Management Interviews

9.2.5.1 Gathering information from managers provides the assessors with an understanding of how the reviewee's ESG programs are managed and intended to be implemented.

9.2.5.2 Typically, the assessors interact and talk with the following people (Note: not all of these people may be at the facility, and may have different titles):

• Site manager(s)
• Production manager(s)
• Maintenance staff
• Environmental, Health & Safety manager(s)
• Quality manager(s)
• Internal assessment manager(s)
• Human Resources manager(s)
• Onsite services staff such as canteen, dormitory supervisors, security staff
• Finance manager/payroll manager(s)
• Procurement manager/supply chain manager(s)
• Warehouse and chemical store manager(s)
• Onsite medical staff
• Legal
• Other personnel

9.3 Site Observation

9.3.1 General Guidance

9.3.1.1 The purpose of the site observation is for the assessors to observe physical conditions and current practices in all areas of the facility.

9.3.1.2 The assessor should have access to all areas of the facility and should set the pace and direction of the site observation. During the site observation, the assessors should endeavor to minimize disruptions to production.

9.3.1.3 It is the responsibility of the reviewee to inform the assessors of the safety rules and requirements, including the use of personal protective equipment (PPE) in specific facility areas, and provide the assessors with necessary PPE where required.

9.3.1.4 There are two parts to site observation, namely site tour and site assessment.

9.3.2 Site Tour

9.3.2.1 Site tour is generally undertaken by the entire assessment team, and it will last for about 30 minutes.

9.3.2.2 At the start of the assessment, a site tour may be conducted. Portions of this site tour may take place prior to the opening meeting.

9.3.2.3 The objective of the site tour is to provide context to the assessors of the reviewee's operation and to help the assessors prepare questions for further investigation.

9.3.2.4 The site tour may consist of:

• Transportation infrastructure
• Emergency services, such as fire department or outside security services
• Identify common areas, overview of company operations
• Identifying potential local community and environmental concerns, which may impact or be impacted by the facility
• Identify Unreasonable restriction on workers' freedom of movement or rights
• Any records or documents displayed that might show a discrepancy between operational activities and the protection of human rights
• Workers' noticeboards and information relating to union or worker's committee meetings
• Understanding the size, scope and location of all building and support facilities
• Quality, production, and time records
• Posting of relevant codes and any worker information relating to their rights

9.3.3 Site Assessment

9.3.3.1 The site assessment is carried out by the EHS assessor, and it will last from 4-8 hours depending on the number of areas / buildings / facilities / dormitories, and canteen to be covered.

9.3.3.2 During the site assessment, the assessor typically inspects in detail all the high-risk areas identified during the site tour (note: not all facilities have the following areas):

• Work environment (space, temperature, lighting, ...)
• Ergonomics and workstations
• Manufacturing and processing operations
• Fire and emergency equipment
• Machine protection and maintenance
• Emergency procedures
• Personal protective equipment
• First aid equipment and medical center/clinic
• Air emissions and emission control systems
• Hazardous materials storage and handling
• Hazardous waste generation and storage
• Waste (hazardous and non-hazardous) management
• Fuel, chemical and oil storage, transport, and use
• Toilets and sanitation
• Canteen and kitchen hygiene and safety, when applicable
• Dormitory facilities including hygiene and safety
• Wastewater treatment, discharge, and sludge disposal
• Recreational facilities

9.3.3.3 Assessors should obtain permission to take photos in the facility. Alternatively, the reviewee can take photos as requested by the assessors and provide them by the end of each day to the assessment team. If the management does not give such permission and will not take requested photos (either as a whole, or in certain areas), assessors will document this in the VAR. Photos are not intended to contain or focus on product, product information or any other proprietary information.

9.3.4 Document Review

9.3.4.1 As part of the assessment, the assessors review relevant records. Examples include:

• Working hour records, payroll, wages, deductions, and benefits
• EHS management system documentation
• Permits/ licenses /approvals
• Waste records
• Written policies, programs, procedures, work instructions
• Training records

9.3.4.2 The records to be reviewed are specified by the assessors to the reviewee during the assessment.

9.3.4.3 The assessors should be thorough in the review of records; however, this does not mean that every record must be evaluated. The assessor may use representative sampling in the review process. Where the assessor does not review every record and there is a non-conformance finding, the assessor must reflect the sampling method in the statement of finding.

9.3.4.4 Unless otherwise stated, the documents and records must be available on-site for assessors to review, and must cover at least the previous 12 months for VA. For payroll, wages, deductions and benefits documents and records must be available for 24 months.

9.3.4.5 Unless otherwise stated, the records shall be available on-site for assessors to review at the start of the assessment and shall cover at least the review period of the assessment. If additional records are requested, they shall be available within 24 hours from the request or before noon on the last day of the assessment, whichever occurs first. If requested records are unavailable as stated, the records shall be excluded by the assessor and result in a finding.

9.3.4.6 As part of the documentation review, the assessors may need to record some information to complete their evaluation. The assessors will not include any confidential information, such as detailed product information, detailed process steps, or personal identifiers in the VAR.

9.3.4.7 Unless otherwise noted, references to percentages of workers in conformance or non-conformance in the VAR are based upon the defined sample.

9.3.5 Daily 'Wrap-up Meeting'

9.3.5.1 Daily wrap-up meetings occur at the end of each day and are approximately 30 minutes or less. During the meeting, the assessor should follow below guidance:

9.3.5.2 If priority non-conformances were identified:

• Discuss any priority non-conformances, including need for immediate correction and/or containment.
• Inform reviewee management that a formal communication of priority non-conformances will be made to the QM, who will in turn notify the assessment customers.
• Make the reviewee aware of any issue, finding, or potential finding where additional information is needed.
• Encourage the reviewee to present/prepare additional evidence or information on local legal requirements, as needed.

9.3.5.3 If no priority non-conformances are identified:

• Discuss preliminary findings, providing the opportunity for the reviewee to provide additional information in the case of a disputed finding.
• Agree upon the agenda for the remaining onsite assessment.
• Clarify any further needs to ensure the assessment is performed as effectively and efficiently as possible.

9.3.6 Closing Meeting

9.3.6.1 The closing meeting is held at the end of the last day of the assessment. The same group of reviewee personnel that participated in the opening meeting, as well as any others who would benefit from hearing from the assessment team, should attend the closing meeting.

9.3.6.2 If the meeting is not conducted or is cut short, reviewees should notify the AQM.

9.3.6.3 The closing meeting includes the following:

• A discussion of all major and priority non-conformance(s), ensuring that the reviewee fully understands those issues.
• A brief discussion of all minor non-conformance(s)
• Discussion of issues in which the assessors need to conduct further studies (e.g. investigate or review relevant legislation) to establish a finding.

9.3.6.4 If priority non-conformance were noted during the assessment:

• Communicate that immediate containment actions are mandatory (unless working hours, recruiting fees and social insurance).
• Immediate containment actions should be completed by the end of the assessment, or as quickly as possible if the issues were discovered late in the assessment.
• Assessor will list the status of the immediate containment actions as "assessor note" in the conclusion of the applicable question in the AR and Assessment Finding Acknowledgement (AFA)¹.
• The AFA is signed by reviewee and lead assessor at the end of the closing meeting.
• Presentation, by the reviewee, of additional evidence or clarification.
• Inform the next steps of the assessment process, including the draft review feedback process.

¹ AFA – A document/ preliminary record of any findings, including priority or major assessment findings (can include other findings if assessor details them). The reviewee is required to sign the AFA at the end of the closing meeting.

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10. Validated Assessment Report (VAR)

The assessment Report (VAR) is a formal document describing the assessment findings and is the basis for the Corrective action plan (CAP).

The assessment Team prepares the VAR and provides it to the AQM. Assessment firms must employ a rigorous internal quality assurance process to ensure that all reports meet the RBA minimum criteria for quality and completeness.

The assessment findings are entered in RBA Online.

• General information about the reviewee, assessment Team, site characteristics
• Executive summary
• Overall assessment score and assessment score detail
• Findings related to the policies, practices, and conditions for the sections of the RBA Code
• Supporting evidence / data

10.1 Assessment Finding Severity Definition

10.1.1 Findings communicated in the Validated assessment Report (VAR) identify good practices and deficiencies. The VAR provides information for the reviewee's management team to improve their ESG programs and performance, related to:

• Intent – what the facility is trying to do
• Implementation – how well the practice meets the defined criteria
• Impact – whether the policies and practices deliver the intended results

10.1.2 Assessors review the evidence gathered during the assessment and evaluate the compliance status for each question of the assessment.

10.1.3 Assessors classify each assessment criteria as one of the following:

10.1.3.1 Priority Non-conformance

A priority non-conformance is any finding leading to:

• i. Imminent Risk to life, limb, facility, the environment, or the community
• ii. Egregious ethical breach

10.1.3.2 Major Non-conformance

• i. Violation of applicable law (see 14.1.2 for extended definition)
• ii. Systemic failure (e.g., same incident multiple times or multiple incidents at the same time)
• iii. Non-conformance situation in which equal or greater than 20% of total sample population is affected.

10.1.3.3 Minor Non-conformance

• i. One-off incident, not likely to repeat.
• ii. A non-conformance situation in which less than 20% of the total sample population is affected.

10.1.3.4 Risk of Non-conformance

If the condition or practice meets minimal conformance with the requirement but would likely deteriorate to a non-conformance without some additional action or effort on the part of facility management.

10.1.3.5 Opportunity for Improvement

A situation which is not fully in conformance or can be improved but where a Corrective action plan is not mandatory but recommended. It is sometimes referred to as an "observation".

10.1.3.6 Conformance

Conformance is noted when the assessor determines that a facility meets or exceeds the assessment criteria and expectations.

10.1.3.7 Not Applicable

Not Applicable applies in cases where a specific operation is missing from the site, for example, facilities that do not have dormitories. In addition, the facility has provided evidence that certain criteria do not apply.

10.1.4 The rating of each assessment criteria has been predefined. However, based on the identified risk, the assessor is free to suggest either increasing the rating (e.g. major to priority) or decreasing the rating (e.g. major to minor). A thorough justification must be provided for any change to the predetermined question significance levels.

10.1.5 The following are examples of risk factors to consider when changing the rating of a finding:

• Health and safety risks to workers
• Health, Safety and Environmental risks to the community
• Significant restrictions or abrogation of worker rights
• Reputational risk
• Operational risk

10.2 Management Exception

If an issue could not be verified prior to the closing meeting, then this is specifically stated in the closing meeting as an exception. Further analysis on this topic is done prior to release of the draft report and the assessment firm informs the reviewee of the conclusion. Exception management of assessment questions should be minimized and should not occur in most assessments.

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11. VAP Appeal and Guidance Mechanism

11.1.1 Appeal Mechanism

In the VAP process, it is possible to challenge a finding or conclusion, or file an appeal on the quality of the VAR. For details of the VAP Appeal Mechanism (VGM) please see: RBA Appeal Mechanism

11.1.2 Guidance and Manual Updates

In the VAP program, the RBA reserves the right to periodically issue updates to this standard and the VAP processes linked in this document. For details of the VAP Standard updates, please see: VAP Manual Guidance Updates

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12. Corrective Action Plans

12.1 CAP Definition and Responsibilities

12.1.1 Corrective action plan (CAP) is an important part of the VAP. The purpose of the CAP is to define corrective actions for resolving any non-conformances identified during the assessment. CAP activities must occur within RBA specified time frames in this manual, to demonstrate closure of any findings identified in the initial assessment. For members, these should be in accordance to the Membership Compliance Guidelines.

12.1.2 The reviewee is responsible for completion of the corrective and preventive actions listed within the plan.

12.1.3 The CAP should include:

• Determination of root cause(s)
• Description of the proposed corrective actions to address root cause(s)
• If reviewee determines that no action will be taken or is necessary in response to a non-conformance, the plan must describe the basis for this determination and why no corrective actions is required.
• Application of a preventive action to prevent future recurrence of the problem or related issue(s)
• The date the action is expected to be completed.
• Current status of the action items

12.1.4 The reviewee must use the CAP template.

• Priority CAPs will be issued by the QM.

12.2 Priority Non-conformance Containment

Upon receiving notification of any priority non-conformance(s) from the assessment Team, the reviewee reviews the non-conformances and initiates containment immediately. Containment is the act, process, or means of immediately reducing a threat or lowering a risk of the situation identified in the priority non-conformance(s).

12.2.1 Priority Non-conformance Timeline

All corrective actions must be completed within the timeframes provided. Any deviations from the prescribed timelines must be approved by the APM. Priority non-conformances (other than exceptions listed in the priority non-conformance section), must be immediately contained.

Timeline	Action	Responsible
0 Hours	Non-conformance identified and communicated to reviewee management during onsite VA	Assessment Team
0 Hours	Reviewee immediately removes the threat (issue which has caused the priority issue)	Reviewee
<1 Hour	Lead assessor to Alert QM with conclusion, immediate containment, data points and supporting evidence	Lead assessor
<12 Hours	QM confirms priority finding to APM	QM
<24 Hours	APM reports issue to Attachment B Companies	APM
<24 Hours	Attachment B Companies contact(s) reviewee to discuss situation and status	Attachment B Companies
<48 Hours	Priority non-conformance action in place (containment in place, reviewee puts in place temporary measures to ensure priority non-conformance does not re-occur)	Reviewee
<48 Hours	Communicate containment action and proof of implementation to Attachment B Companies /QM	Reviewee
7 days*	Full CAP on priority non-conformance(s) is submitted for review to QM	Reviewee
7 days*	Feedback on priority non-conformance CAP and communicates to APM	QM
7 days*	Adjust priority non-conformance CAP if needed	Reviewee
10 days*	Approved priority non-conformance CAP implementation	Reviewee
10 days*	Communicate priority non-conformance CAP to Attachment B Companies	Reviewee/APM
30 days**	APM schedules priority closure assessment	APM
30 days**	Closure assessment of priority non-conformance(s)	Assessment Team
30 days**	Note: If there is sufficient / legitimate evidence that more time is required, reviewee must respond to the APM with the details for the APM to consider.	Reviewee

*Exception:

12.2.2 Priority non-conformance for working hours where working hours is under 84hr/week and/or social insurance (timeline = timeline above plus 1 week)

**Exceptions:

12.2.3 Priority non-conformance for working hours where working hours is > 84hr/week = 90 days

12.2.4 Priority non-conformance for working hours where working hours is under 84hr/week = 180 days

12.2.5 Priority non-conformance for social security = 180 days

12.2.6 Priority non-conformance on fees (code provision A1) = 90 days

12.3 Overall CAP Timeline

The following table shows the rating definitions and associated timelines for VAP findings.

Rating	Finding	Submit CAP	Approved CAP	Progress / Complete CAP
Priority	All findings except those noted below (this includes Working Hour >84 h/week)	1 week from discovery	10 calendar days from discovery	30 days from discovery
Priority	Working Hour ≤ 84 h/week and Social Insurance	2 weeks from receipt of final VAR	6 weeks from receipt of final VAR	180 days from receipt of final VAR
Major	All	2 weeks from receipt of final VAR	6 weeks from receipt of final VAR	180 days from receiving final VAR (guidance only)
Minor	All	2 weeks from receipt of final VAR	6 weeks from receipt of final VAR	In conformance within 270 days from receipt of final VAR
Risk of Non-conformance	All	2 weeks from receipt of final VAR	6 weeks from receipt of final VAR	270 days from receipt of final VAR (guidance only)

VAR – Validated assessment Report

The following table shows the associated CAP timelines for priority non-conformances related to fees.

Rating	Finding	Submit CAP	Approved CAP	Reimbursement Plan	Progress / Complete CAP
Priority	Recruitment Fees (existing workers)	1 week from discovery	14 calendar days from discovery	Reviewee submits: 90 calendar days*	90 days from reimbursement plan approval*
Priority	Departed workers (< 6 months)	1 week from discovery	14 calendar days from discovery	Reviewee submits: 90 calendar days*	270 days from reimbursement plan approval**

* RBA must approve remediation plan; The remediation plan must include implementation steps for no fees recruitment policy(ies). Reviewee must contact RBA compliance team compliance@responsiblebusiness.org if a priority finding is identified.

** Workers resigned within 6 months prior to the last assessment day, the facility has 90 days to make "best efforts" to contact workers that have left the facility within the last 6 months. Workers then have 90 days to request repayment and then those fees must be paid back within 90 days of acceptance.

12.4 CAP Management Options for Non-priority Findings

There are 2 options available for CAP management of non-priority findings.

• AQM managed CAP
• Customer Managed CAP or reviewee Managed CAP

12.4.1 AQM Managed CAP

CAP can be managed using the payable AQM Managed CAP process. The communication on the CAP and its progress is managed by the AQM directly with the reviewee using RBA-Online. APM will communicate with all Attachment B Companies (RBA members only). Therefore, only one CAP is required no matter the number of assessment customers. An AQM managed CAP is strongly encouraged for:

• Reviewees who are providing a corrective action plan to multiple customers.
• Reviewees new to the VAP which could use additional guidance on developing or managing their CAP.
• Reviewees that wish to have a quality review by the RBA AQM team.

12.4.1.1 The AQM is available as a resource, and actions taken suggested in an AQM approved CAP will likely meet the expectations of an assessor during the closure assessment.

12.4.1.2 The option to use the QM Managed CAP process can be confirmed to the APM up to 3 months from the release of the VAR.

12.4.2 AQM Managed CAP is 3 Step Process

1. Review and approval of Root Cause Analysis and immediate containment actions
2. Review and approval of Corrective actions (management system oriented)
3. Monitoring for implementation of corrective actions (12 months)

More information about the CAP process can also be found at: AQM Managed CAP Process

Write to vap@responsiblebusiness.org to request AQM-Managed Service

12.4.3 Process Steps and Timing of AQM CAP Process

The following steps, timelines and process applies to the AQM managed CAP process for Major, minor or risk of non-conformance:

Time	Action	Responsible
0 weeks	Receipt of final VAR and CAP template pre-populated	AQM
2 weeks	Submit completed CAP version 1	Reviewee
2 weeks	Review and provide feedback on CAP version 1 within 48h or approve CAP	AQM
2 weeks	Communicate CAP status and Approved CAP (if applicable) to companies on Attachment B and APM	AQM
4 weeks	Submit completed CAP version 2	Reviewee
4 weeks	Review and provide feedback on CAP version 2 within 48h or approve CAP	AQM
4 weeks	Communicate CAP status and Approved CAP (if applicable) to companies on Attachment B and APM	AQM
6 weeks	Submit completed CAP version 3	Reviewee
6 weeks	Review and provide feedback on CAP version 3 within 48h or approve CAP version 3	AQM
6 weeks	Communicate CAP status and Approved CAP (if applicable) to companies on Attachment B	AQM
6 weeks	Note: If version 3 is not approved then process ends

Timing for follow-up of approved CAP actions:

Time	Action	Responsible
1 month from CAP approval and every following month until CAP completed or maximum of 12 months from the date of implementation of CAP	Provide monthly update of non-conformance CAP implementation progress to APM for a maximum of 12 months	Reviewee
	Submit proof for each non-conformance CAP implementation which has been completed	Reviewee
	Review of non-conformance CAP implementation progress	AQM
	Communicate non-conformance CAP implementation Status to companies on Attachment B	AQM
CAP implementation completed to a maximum of 12 months from the date of implementation of CAP	Closure assessment process management	APM

12.4.4 Escalation

12.4.4.1 If there is a delay in submission of CAP of one week RBA APM will inform the Attachment B Companies (RBA members only). The Attachment B Companies can follow up with reviewee and facilitate, if needed, a timely submission of CAP or implementation updates. The "late" notification is repeated to the Attachment B Companies until receipt of CAP or implementation update is received on a weekly basis.

12.4.4.2 The Attachment B Companies are informed by the APM if the CAP implementation status varies by more than 20 percent versus agreed CAP implementation due date or RBA CAP timeline.

12.4.5 Approval of Corrective Actions

12.4.5.1 The Corrective action plan should be approved by the AQM before any corrective actions are implemented.

12.4.5.2 APM should review and approve the CAP for all non-conformances within 2 days of submission.

12.4.5.3 All corrective actions must be reviewed and approved by the APM before they can be closed. Corrective actions cannot be approved until the reviewee provides a complete CAP and proof of implementation.

Note: The objective of obtaining AQM approval is to ensure completeness of CAP, completeness of implementation, and use of correct RBA tools. It is not an approval or statement of conformance. Conformance can only be determined by a qualified third-party assessment firm upon detailed review through a closure assessment (remote or on-site).

12.4.6 Monitoring Progress

12.4.6.1 For CAPs with implementation periods greater than 30 days, reviewees must provide RBA VAP AQM with status updates at monthly intervals. It is the reviewee's responsibility to submit this to the AQM.

12.4.6.2 Once the reviewee believes the CAP has been fully implemented, the reviewee must provide a final status update indicating the non-conformance has been addressed and provide the appropriate evidence supporting this position.

12.4.6.3 The evidence must be provided in commonly accepted formats (JPEG, PDF, Word.doc, excel, etc.). It is the responsibility of the reviewee to provide evidence in a format that can be accessed by the AQM.

12.4.6.4 Evidence must have the correct references in and to the CAP template to allow easy navigation between CAP template and proof of implementation.

If the Corrective Action has not been closed in the time specified in the CAP or if the corrective action is inappropriate, the reviewee has to provide a proposal to address the issue in the CAP management tool.

Any changes to an approved CAP must be reviewed and authorized by the AQM.

12.5 Customer Managed CAP or Reviewee Managed CAP

There are 2 additional available methods for companies to manage their CAP.

12.5.1 The Customer Managed CAP process requires that the attachment B company (only Member Companies) manage the CAP, working directly with the reviewee.

Requirements for customer managed CAPs:

12.5.1.1 A copy of the approved CAP must be uploaded to the RBA-ONLINE

12.5.1.2 The attachment B company manages the CAP to meet their expectations or reviewee manages the CAP to meet customer(s) expectations.

12.5.1.3 The AQM is NOT available as a resource, nor does the APM verify the actions taken will meet the expectations of an assessor during the closure assessment.

12.5.2 Alternatively, the reviewee can manage their own CAP process and communicate with their customers. (formerly known as auditee managed CAP).

12.6 Root Cause Analysis

The first step in the CAP process is to conduct a root cause analysis for each non-conformance.

"Root Cause Analysis" is a method used to identify underlying cause(s) of a non-conformance. It is used to correct or eliminate the cause and prevent the problem from recurring. If a root cause analysis is not conducted, or conducted poorly, there is a risk that time and resources may only address the symptoms of a problem, rather than addressing the real issue.

The most common element of a root cause analysis includes asking "Why a particular non-conformance occurred?" and documenting the answer.

When considering "Why" a particular problem occurred, it might be useful to consider the following potential elements to ensure comprehensive analysis:

• Knowledge – Did the problem occur due to lack of awareness or knowledge?
• Assignment – Did the problem occur because responsibility was not clearly assigned?
• Tools – Did the problem occur because appropriate tools were not available?
• Training – Did the problem occur due to lack of proper training?
• Accountability – Did the problem occur because little/no accountability, e.g. in a typical situation nothing happens when the task is not done?
• Resources – Did the problem occur due to insufficient resources?

The corrective action to a root cause often requires the examination of one or more of the above management systems for change or improvement.

Example: Consider the case of a worker observed not wearing hearing protection in a high noise area. It may be easy to conclude that the reason was that hearing protection was not provided. However, upon a more thorough evaluation of the evidence, the auditor may find that the auditee was unfamiliar with the regulation requiring the use of hearing protection, or that the worker was not trained on the need to wear hearing protection, or the auditee lacked an enforcement/ reinforcement process. These are more fundamental or root causes of the observed deficiency.

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13. Closure Assessments

All priority non-conformances must be closed through a closure assessment. Completing CAP items, (whether an AQM CAP or an Auditee or Customer CAP) does not close issues, as closure only occurs through a closure assessment.

Major, minor and risk of non-conformance findings may also be closed through a closure assessment.

The timing of the closure assessment should be based upon the type of findings in the initial assessment (Priority, major, minor, risk of non-conformance and whether there are working hours, recruitment fees, and/or social insurance related findings).

The focus of a closure assessment are the issues identified in the initial assessment. However, if an assessor identifies any other finding during any closure assessment, this is to be included as a new issue, following the same process and rules as the initial assessment.

13.1 Priority Closure Assessment

13.1.1 Priority findings are required to be closed by a priority closure assessment.

13.1.2 The purpose of a priority closure assessment is not to achieve conformance for the AC but to remove the condition which triggers the priority rating. Of course, if an AC is verified as conformance during a priority closure assessment because the situation is remediated, and the system fixed to ensure consistent conformance with the AC then a closure assessment for this AC is no longer required.

13.1.3 Closure assessments for priority non-conformance(s) are triggered by the APM. The clock starts when the priority non-conformance is confirmed by the AQM and assessors, which may be:

• During the assessment
• During the draft report stage (when more data is analyzed or during the QM review of the draft report)
• When the rating is changed as per the rating guidance (to correct a mis-rating in draft assessment report)

13.1.4 Priority closure assessments take place:

• For all issues other than recruitment fees, working hours and social insurance: 30 days from discovery
• Working hours and social insurance: 180 days from discovery

13.1.5 Other findings may be closed during the priority closure assessment. However, to be closed it must be agreed upon with the APM during the scheduling process to ensure the priority closure assessment is properly scoped.

13.2 Non-priority Findings Closure Assessments

13.2.1 At the election of the reviewee, major and minor issues can be closed through the same closure assessments or through a separately scheduled stand-alone closure assessment.

13.2.2 Closure assessments for non-priority findings are not scheduled on a set timeline, rather, these are triggered by the reviewee or attachment B company.

13.2.3 Closure assessment timing should reflect 3 months of implementation and align with the corrective action timeframes listed in this document.

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14. VAP Standard

The following notes apply to all provisions herein:

14.1.1 When there is a discrepancy between the RBA code, local law, a participant's policies, or a Collective Bargaining Agreement (CBA), the RBA defines conformance to the RBA code as meeting the strictest requirements (even if it meets RBA code provisions and legal requirements). A Collective Bargaining Agreement may create requirements beyond the RBA Code requirements. The Validated assessment (VA) shall not validate CBA compliance where it is stricter than the RBA Code.

14.1.2 A legal non-conformance is a Major non-conformance unless otherwise stated in a specific provision (e.g., A3.1 if the situation of reviewee is below 60h/w but above local law for ≤40% of the workers) or there is another finding which has a higher non-conformance rating for that provision.

14.1.3 All communications from the reviewee to workers shall be done in a language the worker can understand unless otherwise stated in the provisions. If this is not the case, the relevant aspect is, at minimum, a 'Major' non-conformance.

14.1.4 Guidance applies to all workers, including temporary, migrant, student, and contract, directly and indirectly, employed workers that work in the factory/on production/in the warehouse and any other type of worker/employee unless the AC specifically states a narrower focus group.

14.1.5 Unless otherwise noted, references to the percentage of workers in conformance or non-conformance are based on the defined sample.

14.1.6 A Process is not required to be in writing (unless the AC states specifically it shall be documented). However, all processes shall be verifiably implemented consistently.

14.1.7 Adequate shall mean appropriate and complete for its intended purpose. In practice, it means all required code compliance elements are included in the document (policy or procedure). For example, an adequate policy on prohibition of child labor includes all the elements RBA requires on this code topic.

14.1.8 Effective shall mean successfully achieves its intended goal or outcome. In practice, this means all implementation elements are deployed and the outcome of process/procedure meets the RBA requirement. An effective procedure of child labor will include all RBA required implementation elements such as age verification, personnel files and no children are present or have been hired.

Internal Migrant Workers

14.1.9 Internal migrant workers: Individuals who are recruited and migrate from their usual place of residence to another state or province within their home country for employment purposes. These individuals may differ from the dominant group, often the majority population—in terms of race, color, religion, or cultural origin.

14.1.10 Internal migrant workers shall be considered a separate group, like foreign migrant workers, during the Validated assessment to determine risks and conformance specific to this group.

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References

The following references were used in preparing the RBA Code of Conduct (up to version 8.0) and may be useful sources of additional information:

Standards and Conventions

• ILO Fundamental Conventions
  • Freedom of Association and Protection of the Right to Organize Convention, 1948 (No.87)
  • Right to Organize and Collective Bargaining Convention, 1949 (No.98)
  • Forced Labour Convention, 1930 (No.29)
  • Abolition of Forced Labour Convention, 1957 (No.105)
  • Minimum Age Convention, 1973 (No.138)
  • Worst Forms of Child Labour Convention, 1999 (No.182)
  • Equal Remuneration Convention, 1999 (No.100)
  • Discrimination (Employment and Occupation) Convention, 1958 (No.111)
  • Occupational Safety and Health Convention, 1981 (No.155), and the Promotional Framework, 2006 (No.187)
• OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
• OECD Guidelines for Multinational Enterprises
• United Nations (UN) Guiding Principles on Business and Human Rights
• Universal Declaration of Human Rights
• United Nations Convention Against Corruption
• United Nations Convention on the Rights of the Child
• United Nations Convention on the Elimination of All Forms of Discrimination Against Women
• United Nations Global Compact

Other Useful References

• Dodd-Frank Wall Street Reform and Consumer Protection Act
• Eco Management & Audit System
• Ethical Trading Initiative
• ILO Code of Practice in Safety and Health
• ISO 14001 and related standards – Environmental management
• ISO 45001:2018 - Occupational health and safety management systems
• National Fire Protection Association
• Social Accountability International (SAI) SA 8000
• United States Federal Acquisition Regulation
• UNGPs: United Nations Guiding Principles on Business and Human Rights - https://www.ohchr.org/documents/publications/guidingprinciplesbusinesshr_en.pdf

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RBA VAP Standard V8.0.2 | RBA Public

8.0.2 (2025-04-01)

Added

• Corporate-level GHG implementation foundation section (C6)

Changed

• Education loan threshold increased from 60% to 120% of monthly gross base salary (A1)
• Simplified industrial vehicle driver licensing wording (B1)
• GHG policy reporting scope expanded for corporate vs facility level (C6)
• Simplified next-tier supplier expectation requirements (E4)
• Broadened self-assessment tool references from RBA-specific to generic (E4)

Removed

• Refrigeration requirement for lactation rooms (B1)
• Severe finding threshold for training timeliness in environmental management (CM)
• Severe finding threshold for training timeliness in ethics management (DM)

8.0.1 (2024-01-01)

Added

• Complete criterion library for Code of Conduct 8.0
• Updated scoring framework with revised CAP timelines
• Internal migrant worker provisions across labor criteria
• Enhanced recruitment fee remediation requirements (A1)
• Pandemic and emergency response provisions (B2)
• EU CSDDD regulatory alignment
• German LkSG regulatory alignment
• Spanish (es) and Chinese (zh) translations for all criteria

Changed

• Working hours thresholds updated per Code 8.0 (A3)
• Wage and benefits requirements enhanced (A4)
• Management system criteria restructured with sub-elements (AM)
• Priority finding CAP timeline exceptions for working hours and social insurance
• Scoring framework severity levels refined with clearer definitions