VERIFYING THE SELF-ASSESSMENT QUESTIONNAIRE

　　In completing the Self-Assessment Process, the following lists each question from the Self-

　　Assessment Questionnaire and the evidence that must be verified.

　　PERSONNEL ISSUES

　　Question 1.1 Does the factory obtain current information on local and national laws and

　　regulations, and incorporate this information in its business practices?

　　The workers should be compensated according to the local and national labor laws. The payroll

　　department should have the latest copies of these laws and amendments on file. These laws should

　　cover, but not be limited to the following areas:

　　• Wages and hours.

　　• Legal benefits.

　　• Minimum age for employment and related restrictions.

　　• Health and safety standards.

　　• Employment discrimination.

　　• General labor law.

　　The factory should have a procedure that will ensure that the labor laws and regulations are being

　　followed. There should be a manager or supervisor responsible for monitoring and updating these

　　laws. Any new laws should be adapted as soon as possible.

　　The factory should review the labor laws to ensure that the workers are being properly compensated.

　　If the factory uncovers a violation, that violation must be corrected as soon as possible. The factory

　　should document the violation and what was done to correct it. There should be a procedure to

　　prevent the violation from re-occurring.

　　It should be part of the factories official company policy that all labor laws will be obeyed.

　　Question 1.2 Does the factory prohibit any condition within the facility, building and/or

　　equipment that could cause injury or death to the workers, or any violation of law or a

　　JCPenney standard?

　　An unsafe condition is anything that can cause injury or death to the worker. The factory should have

　　a procedure for monitoring safety conditions within the facility. This would include the building and all

　　property that is attached to the building and owned, or used by the factory. There should also be a

　　procedure for monitoring equipment and machinery for unsafe conditions. These procedures should

　　be monitored by a manager or supervisor. This can be anyone that the factory designates, however,

　　it is usually the responsibility of the Safety Manager or Safety Supervisor. Safety issues concerning

　　machinery and equipment are usually monitored by an Equipment Maintenance Manager or

　　Supervisor.

　　The building should be inspected on a regular basis for unsafe conditions. Unsafe conditions should

　　be repaired as soon as possible. Building inspection records should be maintained indicating the

　　type of inspection performed, date of the inspection and the results of the inspection. Any repairs

　　made should also be listed.

　　Machinery and equipment should be inspected and maintained on a regular basis. Defective

　　machinery and equipment should not be used until the proper repairs have been made. Equipment

　　inspection records should be maintained listing the type of inspection, date of the inspection, the

　　results of the inspection and what repairs were made. Any repairs made should also be listed.

　　All workers using any machinery or equipment should be properly trained in the safe use of the

　　equipment involved.

　　All local and national laws concerning labor issues and the operation of the factory must be obeyed.

　　However, there are situations where a JCPenney standard is more stringent than local or national

　　law. When this occurs, the JCPenney standard must be followed.

　　Question 1.3 Does the factory effectively prohibit convict, involuntary, and forced labor?

　　The use of convict, involuntary, indentured or forced labor of any kind is prohibited. There are no

　　exceptions.

　　Convict Labor

　　The factory is prohibited from hiring convicted criminals currently in prison for committing a crime.

　　Even though there are conditions where it is permitted to employ criminals under local or national law,

　　it is expressly forbidden to import any product into the United States under United Stated Customs

　　Laws, if that product was produced by convict labor.

　　Involuntary Labor or Forced Labor

　　Anyone being forced to work against their will is considered involuntary or forced labor. Workers

　　must be given complete freedom of movement to leave the facility at any time. Factories have the

　　right to impose restrictions on workers entering the facility or entering certain rooms within the facility

　　but should never prohibit workers from leaving.

　　Indentured Labor

　　Workers should never be forced to work by contract or any other means. Workers should never be

　　forced to work to pay off a debt for themselves, a family member or anyone else by signing a

　　contract.

　　Worker Contracts

　　In some factories workers are required to sign an employment contract. These contracts will usually

　　list the job description, job duties, disciplinary procedures, overtime requirements and the length of

　　time that the contract is in effect. Some contracts are open ended. That is, the contract may be

　　written with no ending date. If the contract is open ended, there must be a provision that will end the

　　contract when the worker resigns the job. Employment contracts must not include anything that can

　　be interpreted as forcing the worker to work. Workers must be allowed to resign at any time.

　　Occasionally factories use third party agents or brokers to hire workers. If third parties are used to

　　hire workers, the workers’ wages must be paid directly to the worker and not the agency or broker. It

　　is the factories responsibility to ensure that third party agents or brokers supply legal workers that are

　　not convicts, indentured or forced to work in any way.

　　Security guards employed by the factory, or security agencies contracted for their services, must not

　　engage in practices that will cause workers to stay in the factory and work against their will. Security

　　guards should be limited to normal security functions such as protecting the factory and products

　　produced and the security of the workers and other factory personnel.

　　The factory should not retain the worker’s original identification card, work permit or other form of

　　identification.

　　Employees must have freedom of movement within the dormitories and be free to leave at any time.

　　Question 1.4 Does the factory obtain documentation for proof of age and eligibility for

　　employment from all potential workers prior to hiring?

　　When hiring workers, the factory should verify proof of age and eligibility to work according to local

　　and national laws or JCPenney standards. This proof must be in a form of legally acceptable

　　documents. The following are examples of the type of documents that are acceptable:

　　Proof of age as required by the country where the factory is located, including but not limited to:

　　• Official birth certificate.

　　• Official identification card.

　　• Official school records.

　　• Proof of residence.

　　• Immigration or other legal papers as required.

　　• A statement of age containing:

　　• Employee signature.

　　• Employee identification number or other means of identification.

　　• Date of signature.

　　All workers should fill out an employment application listing their name, address, date of birth, place

　　of birth, citizenship, type of job applied for and any information as required by local and national law.

　　This application should be signed by the worker.

　　The factory should have a procedure that explains to the workers minimum age and eligibility

　　requirements for the job applied for. The factory should explain all benefits that the workers are

　　entitled to. This includes social security (medical and pension), savings, bonus, overtime hours,

　　overtime pay, worker contracts, job requirements, disciplinary procedures, dormitory, meals and

　　anything that will affect the worker.

　　All benefits and requirements should be prominently posted so they can be read by all the workers.

　　All worker personnel records should be periodically reviewed to ensure that the proper documents are

　　on file and correctly updated.

　　Question 1.5 Does the factory prohibit the hiring of workers under the legal age or

　　JCPenney standard, or ineligible workers, and does the factory keeps copies of age and

　　eligibility?

　　It is the responsibility of the factory to ensure that all workers hired are of legal age and meet the

　　eligibility requirements of the country where the factory is located. If it is determined that these

　　requirements are below the JCPenney standards, then the JCPenney standards will apply.

　　The factory should have a procedure to screen all workers prior to hiring, to ensure that they meet all

　　applicable age and eligibility requirements. Copies of all applicable proof should be kept on file for all

　　workers.

　　There should be a manager or supervisor responsible for maintaining and updating worker files.

　　Question 1.6 Does the factory effectively prohibit all forms of harassment, abuse, and

　　physical and/or verbal abuse?

　　Workers should be fairly treated according to the laws of the country where the factory is located.

　　The factory should expressly prohibit all forms of harassment, verbal and/or physical abuse. This

　　includes, but is not limited to:

　　• Physical or verbal coercion.

　　• Sexual abuse.

　　• Harassment, or abuse in the form of disciplinary action.

　　• Any harassment or abuse from any person, such as security guards, or any manager, supervisor

　　or worker.

　　Question 1.7 Does the factory have procedures to ensure employees are compensated

　　in accordance with local laws and regulations?

　　The factory should have a payroll procedure that will ensure workers are compensated in accordance

　　with local and national laws. The factory should have a manager or supervisor responsible for the

　　payment of wages and all issues relating to wages. There should be an itemized listing of all

　　deductions. These procedures should include, but not be limited to:

　　• A detailed method of payment as appropriate.

　　Check.

　　Cash.

　　Direct deposit.

　　• The basis for payment.

　　Hourly.

　　Weekly.

　　Monthly.

　　Piece rate.

　　Combination (Hourly and piece rate).

　　• A detailed procedure for wage calculation where applicable.

　　Quota for piece rate or hourly calculation.

　　Adjustment to meet minimum.

　　Hourly or monthly minimum rate.

　　Bonus or other incentives.

　　• Itemized deductions.

　　Social Security (Medical and/or pension).

　　Required local and national taxes.

　　Issuing and repayment of loans.

　　Any other deductions.

　　• Frequency of payment.

　　Weekly.

　　Monthly.

　　Other.

　　• Specific length of the normal work day.

　　Number of hours.

　　Start and finish time.

　　• Define the normal week.

　　Number of consecutive days.

　　Specific days of the week.

　　• Rest and meal breaks.

　　Number of breaks.

　　Length of break.

　　Time of day or shift.

　　• Designate days off.

　　Normal day(s) off each week.

　　Holidays (Legal and/or religious).

　　Vacation.

　　• Define overtime.

　　Hours.

　　Compensation rate.

　　The factory should have a detailed pay slip that shows all the deductions made and the method of

　　calculation. If workers receive cash payments there should be a master payroll record with each

　　workers’ signature indicating that they received their pay.

　　The workers should be notified in writing of any changes in their actual pay and/or payroll procedures

　　and the reasons for these changes.

　　Any miscalculations or under payment of wages must be corrected immediately.

　　Any worker’s complaints regarding wages must be investigated immediately. If it is determined that

　　the workers were not correctly paid, an adjustment must be made immediately.

　　Question 1.8 Are factory workers, at the time of hiring, made aware of their legal rights

　　regarding hours worked, and wage compensation?

　　When factory workers are hired they should receive an explanation of their legal rights concerning the

　　working hours of the factory. They should be told if overtime is required and how many overtime

　　hours they can expect to work daily, weekly and monthly. They should be given an explanation of the

　　laws concerning overtime.

　　A written explanation of wage and overtime laws should be provided to the workers. This explanation

　　should be signed by the worker and a copy should be kept in the worker’s file.

　　The factory should periodically review the laws concerning hours worked and wage compensation to

　　ensure they are in compliance with the most current laws. Any areas that are not current should be

　　corrected. Copies of the latest laws should be kept on file.

　　Question 1.9 Does the factory prominently post minimum wage rates, allowance

　　information, benefits policies, and regular and overtime wages in the native language(s) of the

　　factory workers and management personnel?

　　The factory should list its policies concerning minimum wage rates, regular working hours, overtime

　　hours and benefits. Any applicable local and national wage laws should also be listed. These

　　postings should be located in prominent areas, i.e., the worker entrance, time clock, or cafeteria; so

　　the workers can read them at any time.

　　All postings should be in the native language of the factory workers and factory management

　　personnel. In the event that the factory hires workers that speak a language other than the language

　　of the country where the factory is located, these postings should also be in that language. It is

　　possible that the factory will need postings in more than one language.

　　Question 1.10 Does the factory have, utilize, and maintain an organized payroll system

　　including an accurate time recording device?

　　The payment of wages can be a complicated process. To ensure that the workers are accurately

　　paid, an organized payroll system should be used. A computer payroll system is recommended for

　　accuracy and consistency. All methods of payment, including time work, piece work, incentives,

　　bonus, and etc., should be part of the payroll system. All benefits and allowances such as meals,

　　housing, uniforms, etc., should be included. All deductions such as social security (medical and

　　pension), taxes, loans, and etc., should also be included.

　　If the factory is not equipped for an organized or automated payroll system, a commercial payroll

　　service, if available, is an acceptable alternative.

　　For piece rate and/or quota payments, employee sign-off sheets should be available confirming the

　　correct unit counts. The employee should sign off on any random re-counts that are used for

　　verification.

　　Since accurate payroll calculations are based on the time that the factory workers work, an accurate

　　time recording device such as an electric or electronic time clock should be used. The time clock

　　should be periodically checked for accuracy. Each worker should have their own time card to record

　　time in and time out including meal breaks and rest breaks. If an electronic recording device is used,

　　each worker should have a worker identification card to record time in/time out, meal breaks and rest

　　breaks. The factory should maintain a summary sheet listing the time worked for all the workers.

　　The factory should perform periodic reviews to determine the accuracy for the method of paying the

　　workers. Mechanical and electronic equipment should be checked to ensure that it is in proper

　　working order. If this equipment is found to be inaccurate, or not in working order, corrective action

　　should be taken, including adjustment of back wages, if required, for the period of time when the

　　equipment malfunctioned.

　　Question 1.11 Does the factory produce and retain payroll records to support

　　compensation, including the payment of overtime and the deduction or required taxes?

　　The factory should keep payroll records for at least one year or longer if required by law. Payroll

　　summaries should also be retained with the following information:

　　• Name and identification number of each employee.

　　• Hourly, weekly, monthly rate or piece rate if applicable.

　　• Payment of minimum wage.

　　• Gross pay.

　　• Net pay.

　　• Pay period.

　　• Payment date.

　　• Minimum wage.

　　Question 1.12 Does the factory provide all employees with pay information which details

　　the current period’s wage calculation?

　　The factory should provide each worker with a pay stub or some other form of documentation listing

　　the details for the pay period involved. This information should include, but not be limited to:

　　• Total hours worked including regular and overtime hours.

　　• Gross wages including advances or loans.

　　• Calculation of overtime, quota incentive and piece rate if applicable.

　　• Make up pay for piece rate under the minimum wage.

　　• Social Security, pension, savings.

　　• Other deductions including repayment of loans.

　　• Net Pay.

　　The factory should periodically interview workers, selected at random, to verify that they have

　　examined a detailed pay record and that they understand the calculation of their gross pay and net

　　pay. Any deviations from the established procedures are to be corrected in a timely manner.

　　Question 1.13 Does the factory pay piece rate workers at a rate equivalent to the minimum

　　wage required by law?

　　The factory must ensure that all workers earn the minimum rate according to law. If a piece rate

　　worker cannot make the standard, the factory must adjust the standard of the wage rate so that the

　　workers wage will be equal to the legal minimum wage. The worker should be advised of this and the

　　payroll records should reflect this adjustment.

　　Question 1.14 Does the factory ensure that the workers do not work more hours per day

　　and per week than the legal limits, or the JCPenney standard?

　　There are times when it is necessary for a factory to work overtime to meet production and delivery

　　schedules. However, workers who work excessive hours will loose efficiency and production will

　　decrease. In addition, the injury rate will increase.

　　Workers must not exceed the maximum number of hours allowed by law or the JCPenney standard.

　　In the event that there is no local or national law governing maximum working hours or current law is

　　in conflict with the JCPenney standard, then the JCPenney standard will apply.

　　If the factory determines that it is necessary to work more hours then allowed by law, they must

　　obtain a waiver from the appropriate governing authority. This waiver must list the period time

　　covered and the amount of hours to be worked. Workers must be paid for extra overtime according

　　to local or national law.

　　The department or individual responsible for payroll must perform periodic time card reviews to

　　ensure the hours worked by employees (voluntarily or involuntarily) in a given day, week or month do

　　not exceed legal limits. If official waivers have been issued, the limits of the waiver must not be

　　exceeded.

　　Question 1.15 Does the factory have policies that explicitly prohibit discrimination?

　　The factory must hire workers based on their ability to do the job not on any physical or personal

　　characteristics or beliefs.

　　The factory must have a policy that expressly prohibits all forms of discrimination. The workers must

　　be made aware of this policy.

　　HEALTH AND SAFETY

　　Question 2.1 Does the Factory comply with national and local health and safety laws and

　　regulations?

　　The factory must provide a safe working environment for the workers. The building must be in good

　　repair with no safety hazards. Procedures should include, but not be limited to:

　　• A plan for fire safety.

　　• Adequately equipped first aid kits.

　　• Easily accessible sanitary drinking water in work and residential areas.

　　• Sanitary toilet facilities.

　　• Adequate ventilation throughout building and dormitory.

　　• Structurally sound and clean building facilities, including dormitories.

　　• Machinery and equipment that is safe and will not cause injury to the workers.

　　• Emergency evacuation plans, in the native language(s) of the employees, posted in view of

　　factory workers (i.e. a diagram of the factory layout with emergency exits and routes highlighted).

　　The factory should maintain inspection records and operating permits for building and equipment as

　　required by law. This should include, but not be limited to:

　　• Inspection certificates and citations issued by government agencies.

　　• Operating permits issued by government agencies.

　　• Health and safety reports detailing findings, recommendations and corrective actions.

　　• Machinery inspection and maintenance reports issued by factory management.

　　• Fire extinguisher inspection records noting dates inspected and expiration.

　　• Records of fire safety drills including the dates held and any pertinent details on the results of the

　　drills.

　　• Work injury reports including the nature and frequency of accidents.

　　• Clinic logs listing the reason for visit.

　　The factory should comply with all local and national government health requirements. Records and

　　correspondence should be maintained for any on site inspections. Deficiencies discovered during

　　these inspections should be recorded. The factory should correct all deficiencies and notify the

　　appropriate government agency for a re-inspection. Records should be maintained of the reinspection.

　　Once the factory passes the re-inspection, all documentation should be kept as evidence

　　of the passed inspection.

　　Question 2.2 Does the Factory have procedures for machinery and equipment, and

　　chemical safety?

　　The factory should have procedures in place for the safe operation and use of machinery and

　　equipment. This should include the handling, use and storage of chemicals. These procedures

　　should include, but not be limited to:

　　• Machinery and equipment safety:

　　Training workers in the safe use of machinery and equipment.

　　Providing appropriate personal protective equipment, free of charge, to factory workers and

　　requiring them to use it. This equipment includes:

　　Respiratory protection

　　Skin protection

　　Eye and face protection

　　Hearing protection

　　Foot protection

　　Hand protection

　　Head protection

　　Providing appropriate safety guards and features on all machinery and equipment and ensuring that

　　they are functioning properly.

　　Ensuring through routine inspection that electrical equipment and outlets are not overloaded.

　　Ensuring that boilers have operational pressure release valves.

　　• Chemical safety:

　　Ensuring proper storage of hazardous and toxic materials.

　　Providing periodic physical exams for workers handling hazardous materials.

　　Training workers in chemical safety.

　　The factory should perform the following functions to ensure that the workers are performing under

　　the safest conditions possible:

　　Periodically review all safety procedures to ensure that they are adequate and being followed by the

　　workers.

　　Develop programs and materials to train workers and managers on procedures for machinery and

　　equipment and chemical safety.

　　Train the workers on the use of personal protective equipment and safety guards. This equipment

　　should be accessible and the workers should be required to use it.

　　Store hazardous or toxic materials properly.

　　Continually inspect equipment and machinery to ensure proper operation of required safety features

　　and that the workers using this equipment are properly trained.

　　Periodically review files to ensure required health and safety records are appropriately maintained

　　and distributed.

　　Require the workers to follow all safety procedures and discipline workers who do not.

　　Question 2.3 Has the Factory implemented procedures for fire safety which include

　　worker housing and dormitories?

　　Fire safety is extremely important. The factory should have procedures in place that will ensure the

　　workers are protected against fire and fire related hazards. This should include worker housing.

　　The building and/or dormitory should have fire extinguishers placed in every room. A fire extinguisher

　　should be placed within 50 feet of each worker, and be of an appropriate size that can be handled by

　　the average worker. The type of fire extinguisher used depends upon the type of fire. For example,

　　an area that uses electrical equipment will need a different type of fire extinguisher than an area

　　where chemicals are used. All workers should be trained in the proper use of fire extinguishers. In

　　addition, selected workers should receive extensive fire training and be organized as a fire fighting

　　brigade. Fire extinguishers are intended for spot fires which are usually small fires. These fires can

　　start by spontaneous combustion, defective or overheating machinery and equipment, careless

　　smoking or other causes. Sprinkler systems, fire hoses or other fire fighting devices are intended for

　　large fires, but should not replace fire extinguishers. Fire extinguishers should be serviced annually.

　　Each fire extinguisher should be tagged indicating the date and type of service.

　　The building should have enough emergency exits to allow the workers to leave the building in a fast

　　and orderly manner. Exits should be on opposite sides of the building. If the building is more than

　　one story there should be sufficient stairways to allow the workers to get to the ground floor and exit

　　the building in a fast and orderly manner. A traditional fire escape on the outside of the building is

　　preferred, however, any stairway that leads to the ground floor and is near an exit to the outside is

　　acceptable.

　　All exits should be clearly marked and accessible. Exits must not be locked or blocked in any way. If

　　building security or theft is a concern then push bars should be used on the exit doors. This will

　　prevent the door from being opened from the outside, but allows the door to be easily opened from

　　the inside in case of an emergency. For additional security an alarm can be installed on the door to

　　advise security personnel when it is opened.

　　The factory should conduct periodic fire drills to ensure that all workers know how to leave the

　　building in a fast and orderly manner.

　　The factory should have procedures to train all managers and workers in fire safety.

　　The factory should develop a fire evacuation plan. This plan should clearly define the nearest exit

　　path and be prominently posted for the workers. For large buildings, several evacuation plans should

　　be posted at different locations throughout the building.

　　The factory should conduct periodic fire safety inspections of the building, machinery and equipment.

　　Any failure of this inspection should result in immediate corrective action.

　　FACILITY AND ENVIRONMENT

　　Question 3.1 Is there sufficient work space for each worker to perform their duties in a

　　safe manner without interference from other workers, machinery or equipment, and raw

　　materials used in production?

　　The factory should be designed and operated in a manner that will allow sufficient area for each

　　worker to perform their duties without interference from other workers. This area should include

　　sufficient space for materials, tools and other items that are necessary for manufacturing the product.

　　There should be sufficient room between workers to allow them to leave their work area in a fast and

　　orderly manner in case of fire or other emergency. Each work station should have adequate lighting

　　to reduce the risk of eye strain.

　　The factory should perform periodic inspections to ensure that the condition of each work station is

　　safe and well lit. Any defective areas should be repaired or replaced as required. Work station

　　inspection records and a corrective action procedure should be maintained.