Global Social

Compliance Programme

Reference
Environmental
Audit Process
& Methodology
November 2010
About the GSCP
Global Social Compliance Programme

/ GSCP objectives and scope / Users & Usage

The Global Social Compliance Programme is a business‐driven These tools are openly available for all to use. Users
programme for the continuous improvement of working can include GSCP member and non‐member buying
and environmental conditions in global supply chains. companies, suppliers and employment sites. Multi‐
The GSCP was created by and for global buying companies Stakeholder Initiatives and other initiatives, auditing
(manufacturers and retailers) wanting to work collaboratively bodies and other scheme owners can and are encouraged
on improving the sustainability (social and environmental) of to also use the GSCP Reference tools.
their often‐shared supply base. To this end, these companies
The Reference tools can voluntarily either be:
seek to harmonise existing efforts to deliver a shared, global
and sustainable approach. • integrated by users into their respective systems; or
The scope of the Programme encompasses: • utilised by users as a reference against which to
compare their existing tools through the GSCP
• social and labour practices,
Equivalence Process1.
• site‐specific environmental practices
(not product related).
/ Responsibility
The Programme can be applied at all levels of the supply
The GSCP does not monitor nor audit in any way the
chain.
compliance by a user’s supply chain with the GSCP
The Programme is neither a monitoring initiative, nor Reference tools or any standards.
a substitute to existing systems. The GSCP will not
The adoption of part or all of one or more Reference
undertake accreditation or certification activities as it
tools cannot be put forward as a proof of adequate
must remain a non‐aligned, neutral reference framework.
due diligence. The responsibility of the implementation
of these tools, of the monitoring of the user’s supply
/ The GSCP Reference tools chain’s compliance and of any due diligence linked to
it, resides with the user. Any use of the GSCP name or
To drive convergence, the GSCP has developed a set of
logo has to follow the terms established by the GSCP.
Reference tools and processes that provide a common
These terms are available on the GSCP website (www.
interpretation, based on best existing practice, of fair
gscpnet.com).
labour/social and environmental requirements and their
implementation in the supply chain.

1. The Equivalence Process is a mechanism by which a social and/or environmental compliance scheme is objectively benchmarked against the requirements defined in
one or more GSCP Reference tools, to determine their level of equivalence. Through the Equivalence Process, the GSCP enables the comparison of various standards and
schemes against the GSCP Reference tools, aiming at bringing convergence in requirements and approaches and building mutual recognition.

The Consumer Goods Forum

The GSCP is housed by The Consumer Goods Forum, a retailer and manufacturer parity industry body, driven by its
members2. It brings together retailers, manufacturers and suppliers to collaborate across the value chain to enrich
shopper and consumer value in all markets. It supports processes and practices that optimize the value chain as an
interrelated whole, in accordance with all anti-trust laws.

2. For more information, please visit www.theconsumergoodsforum.com

Acknowledgments
Thank you to those who contributed to this Reference tool

This Reference tool has been developed by supply chain experts from GSCP member companies, with input from key
stakeholders, including other brands and retailers, initiatives and international organisations, auditing and certification
bodies and civil society representatives. The GSCP would like to thank all those who have helped with the development
and continuous improvement of this Reference tool.
 Global Social
Compliance Programme

Table of contents
// Introduction 02

// 1. Risk assessment system 04

1.1 Self-assessment questionnaire 04

// 2. Audit request 05
2.1 Launching the audit request 05
2.2 Pre-audit employment site profile 05

// 3. Preparation 06
3.1 Background and context review 06
3.2 Audit organisation 06
3.3 Communicating the audit arrangements 08
3.4 Supplier preparation 10

// 4. Audit execution 11
4.1 Opening meeting 11
4.2 Employment site tour 12
4.3 Interviews 13
4.4 Document review 14
4.5 Alert notifications 15
4.6 Audit team pre-closing meeting 16
4.7 Closing meeting 19

// 5. Audit outputs 19
5.1 Audit report 19
5.2 Supplementary audit information 20
5.3 Information management 20
5.4 Audit follow-up 21

// Glossary of terms 22

// List of appendices:
There are seven reference tools available that complement the audit process described above by providing further
reference guidelines and templates for carrying out the described process. These are:
Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire
Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile
Appendix 3: GSCP Reference Environmental Audit Checks
Appendix 4: GSCP Reference Environmental Alert Notification
Appendix 5: GSCP Reference Environmental Audit Report
Appendix 6: GSCP Reference Environmental Supplementary Audit Information
Appendix 7: GSCP Reference Environmental Summary of Findings and Corrective Actions

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introduction

Reference Environmental Audit Process & Methodology - november 2010

Risk Assessment System

about The GSCP Reference tools

on Environmental Audit Process
& Methodology
Audit Request

Scope & usage:

The reference tools on Environmental Audit Process complement the audit process. They apply to the auditing
and Methodology are part of the GSCP set of reference of sites from all sectors, categories and countries. They are
tools designed to provide a common interpretation of applicable to first party, second party and third party audits.
environmental requirements and their implementation.
Preparation

The reference tools on Environmental Audit Process and

The reference tools on Environmental Audit Process and Methodology are based on the GSCP Environmental
Methodology detail the requirements that should be met Reference Requirements but can be adopted and tailored to
by buying companies and auditors to conduct best practice other codes of environmental practice.
environmental audits of an Employment Site’s performance.
The reference tools are not a substitute for existing audit
The reference tools cover all steps to be taken prior, during
process or existing systems.
Audit Execution

and after an audit and include, where relevant, templates to

Overview of the audit process

The REFERENCE TOOL ON ENVIRONMENTAL AUDIT • by developing a Best Practice manual giving examples of
PROCESS is designed to provide best practice guidance for “what good looks like” against each topic, with practical
Audit Outputs

the audit process. After benchmarking existing processes, advice on ways to address common environmental
the members of the Expert Working Group on Audit Process compliance issues;
& Methodology developed the following process.
• by encouraging suppliers to request environmental
compliance audits themselves. This can be promoted
Involvement of suppliers in the audit process as a way of prompting continuous improvement or of
demonstrating their own commitment to environmental
Glossary

Suppliers should be involved as much as possible in the audit compliance.

process.
This can be done:
• by sharing briefing notes with the supplier explaining
Appendices

the background, process, applicable codes and audit

methodology;

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 introduction
Reference Environmental Audit Process & Methodology - november 2010

Risk Assessment System

Audit process

RISK ASSESSMENT SYSTEM

STEPs GSCP REFERENCE TOOLs

 ollect risk criteria, for example by evaluating:

C • Réference Environmental Self-Assessment Questionnaire

Audit Request
• Country of employment site (Appendix 1)
• Industry
• Processes
• Material use and storage
• Sensitivity of local environment/ecosystems
• Self-assessment questionnaire (optional)

Preparation
REQUEST FOR environmental AUDIT
STEPs GSCP REFERENCE TOOLs

• Initial communication with employment site • Reference Environmental Pre-Audit Employment Site

Audit Execution
• Collection of site information Profile (Appendix 2)

PREPARATION
STEPs GSCP REFERENCE TOOLs

• Background and content review • No specific tools (une information from Reference

Audit Outputs
• Audit organisation: type, team Environmental Self-Assessment Questionnaire [Appendix 1]
• Communication of audit arrangements and Reference Environmental Pre-Audit Employment Site
• Supplier preparation Profile [Appendix 2])

AUDIT execution

Glossary
STEPs GSCP REFERENCE TOOLs

• Opening meeting • Reference Environmental Audit Checks (Appendix 3)

• Site tour • Reference Environmental Alert Notifications (Appendix 4)
Appendices

• Management and worker interviews

• Document review
• Audit team pre-closing meeting
• Closing meeting

AUDIT OUTPUTS
STEPs GSCP REFERENCE TOOLs

• Audit reporting • Reference Environmental Audit Report (Appendix 5)

• Follow-up and verification (if required) • Reference Summary of Environmental Findings
and Corrective Actions (Appendix 6)

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Reference Environmental Audit Process & Methodology - november 2010

Risk Assessment System

1. Risk Assessment System

A buying company should have in place an efficient process and/or previous audit results. However, it should be noted that
to measure environmental compliance and identify potential this is not intended to be an exhaustive list.
risks in its supply chain. This will enable the company to
This information upon which the risk assessment is based
focus attention on key areas of potential risk and direct its
Audit Request

should be provided by the supplier or employment site either

audit resources accordingly.
through a self-assessment questionnaire (Appendix 1) or
Relevant environmental risk criteria may include: geographical through other existing tools. The risk assessment approach
area, sensitivity of local environment/ecosystems, employment should ensure that potential risks are prioritised and are
site function, energy use, emissions to air, land and water, appropriate and representative of the employment site and
hazardous substances use and storage, waste management, the nature of its activities.
pollution prevention, major incident prevention and
Preparation

management, environmental nuisance, licences and permits,

1.1 Self-assessment questionnaire

Audit Execution

The self-assessment questionnaire is an optional tool and Companies should communicate the following to employment
can be used by: sites when requesting this information:
• a buying company to risk assess suppliers/employment • reason for the information request;
sites (e.g. to provide a basis for the development of an
• how the risk assessment fits within the audit process;
audit programme);
• to whom to send the completed self assessment (or how to
• a supplier or employment sites as an aid to their own
upload the self assessment on to a database);
Audit Outputs

risk reviews and/or preparation for their own self audit

programmes; and • timeframe for completion;
• an auditor to focus on site investigation on high risk areas. • process and timeframe for updating the self-assessment.
A reference self-assessment questionnaire is available in
Appendix 1.
Glossary
Appendices

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Reference Environmental Audit Process & Methodology - november 2010

Risk Assessment System

2. Audit Request
2.1 Launching the audit request
An audit request may be made by: • a ny other party with an interest in the commercial relationship

Audit Request
and environmental performance of the employment site.
• the employment site;
For example, industry or monitoring bodies.
• the supplier;
Any company/organisation requesting an audit is termed an
• the buying company; ‘audit requestor’.

Preparation
2.2 Pre-audit employment site profile
When an audit request is made, the auditor may supply • the pre-audit employment site profile should be completed
the employment site with a pre-audit employment site and returned to the auditor two weeks from the date of
profile questionnaire. However, the use of the pre-audit the request being made;

Audit Execution
employment site profile questionnaire is at the discretion
• if an audit is requested and scheduled in less than two
of the audit requestor. The pre-audit employment site
weeks, the auditor and employment site should work
profile questionnaire asks for general information about the
together to ensure the pre-audit employment site profile
site, for example its: location, size, production processes,
is returned as soon as possible, and in any event before the
licences and permits, energy use, sources of emissions to
audit is carried out.
air, land and water, hazardous substances use and storage,
waste management, pollution prevention measures, major A pre-audit employment site profile should have four main
incident prevention and management and environmental areas:

Audit Outputs
nuisance. This information allows auditors to:
1. s upplier overview;
• prepare relevant briefing materials (industry or country-
2. e mployment site overview;
specific);
3. e mployment site details;
• plan the assessment, for example in relation to the
experience and language capabilities of the audit team 4. a summary of activities routinely undertaken by contractors
members and the required number of auditor days (cf. on-site.

Glossary
3.2.2 Audit length);
Where the employment site itself is the audit requestor, the
• focus the audit on potential high environmental risk areas. auditor should ensure that an agreement is in place with the
employment site to allow the auditor to communicate audit
The audit company should communicate the following
findings and alert notifications to relevant customers.
to each employment site to be audited and any relevant
Appendices

parties, such as agents, in the supply chain: A reference pre-audit employment site profile is available
in Appendix 2.
• the importance of accuracy in completing the pre-audit
employment site profile;
• timeframe for completion of the pre-audit employment
site profile;
• to whom to send the completed pre-audit employment
site profile.
Recommended timeframe:
• the auditor should supply the pre-audit employment site
profile to the employment site within five working days of
the audit being confirmed;

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Background and context review

Reference Environmental Audit Process & Methodology - november 2010

Risk Assessment System

3. Preparation
Audit organisation

3.1 Background and context review

The auditing organisation or auditor must be fully aware of environmental legislation and regulatory requirements that
Audit Request

the conditions, challenges and issues prevailing in the country, may apply to the employment site. This should include an
region and industry where the audit is to be conducted. understanding of non-mandatory schemes and certifications
The auditing organisation and/or the auditor should be such as those for environmental management systems
Communicating the audit arrangements

knowledgeable and aware of the issues which could impact (EMSs) to the internationally recognised standards of
the environment in the country, region or industry/industrial ISO14001 or EMAS. The auditing organisation or auditor
sector concerned. The auditing organisation or auditor should also have knowledge of what constitutes operational
should have a detailed awareness of the local and national best practice within the industrial sector in question.
Preparation

3.2 Audit organisation

3.2.1 Audit type To minimise the event that - due to the lack of special
Audit Execution

preparations - necessary information and personnel may not

Audits should take place during a period when the employment be available on the day of the visit to complete the audit,
Supplier preparation

site is in operation. the buying company should clearly communicate its policy
on unannounced audits to suppliers and employment sites.
Audits may be: The policy should state that:
• unannounced (the employment site has no prior warning • audits may occur at any time on an unannounced basis;
of the audit);
• employment sites may be required to provide self
Audit Outputs

• semi-announced (whereby the employment site is aware assessment information on a regular basis and this
that an audit will take place during a given time period, but information must be accurate;
the actual date of audit is not communicated);
• auditors presenting the correct credentials should be
• announced (at a mutually convenient date agreed with allowed full access to the employment site;
employment site).
• the necessary records should always be kept on the
In all cases, the buying company should clearly communicate employment site or be readily available (cf. 3.4 Supplier
Glossary

its audit policy and process (including the reference Preparation).

standard against which audits are conducted as well as
the expectations in case of non-compliance detected) to > Semi-announced audits
suppliers and employment sites as part of its commercial
terms. The buying company’s policy may include provision Buying companies should clearly communicate their policy
Appendices

for all types of audit under certain circumstances. on semi-announced audits to suppliers and employment
sites. The policy should include the following points:
The risk assessment process can be used to influence the
type of audit selected. For example, the audit requestor • the buying company will specify a window during which an
may decide to execute semi-announced audits in all high audit may take place. Audit windows may range between 2
risk employment sites. However, other considerations such weeks and 2 months;
as the relationship with the employment site should be • all employment sites are required to provide up-to-
taken into account since semi-announced and unannounced date and accurate pre-audit and, when requested, self
audits can negatively impact supply chain relationships. assessment information at the beginning of the window;
> Unannounced audits • auditors presenting the correct credentials during the audit
window should be allowed full access to the employment
Unannounced audits allow auditors to assess the operations site;
and activities at the employment site in their ‘normal state’,
since the employment site has not had the opportunity to • the necessary records should be kept at the employment
make any special preparations. site during the window.

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Background and context review
Reference Environmental Audit Process & Methodology - november 2010

Risk Assessment System

> Announced audits 3.2.2 Audit length
The right to perform an announced audit should be a normal

Audit organisation
part of the commercial relationship. However there is a risk The number of auditor days at the employment site should
that employment sites may make special preparations for be based on, for example, the size and complexity of the site
the audit and best practice is to use a mix of announced, and the type of operations with the potential to impact the
semi-announced and unannounced audits to mitigate this environment. The length of the audit should allow sufficient
risk. Buying companies should clearly communicate their time to undertake a site tour of the complete site, interview
policy on announced audits to suppliers and employment a number of workers, including individuals who have direct

Audit Request
sites. The policy should include the following points: environmental roles and responsibilities and to undertake

Communicating the audit arrangements

a review of applicable documentation. The length of the
• the buying company will agree an audit date with the audit should be agreed between the audit requestor and the
employment site in advance; auditor based on existing knowledge of the site and area and
• the employment site is required to provide up-to-date and the information provided in the Self-Assessment and/or Pre-
accurate pre-audit and, when requested, self assessment Audit Employment Site Profile questionnaire.
information in advance of the audit; In the case of agricultural businesses, consideration should

Preparation
• auditors presenting the correct credentials on the date of be given to the size and geographical spread of the business
the audit should be allowed full access to the employment and the number of growing locations to ascertain person
site; days required.
• the necessary records and the concerned personnel should The following provides an indication of the length of audit
be available at the employment site on the day of the audit. for different sites:

Audit Execution
Supplier preparation
Indicative Length
Site Description of Audit

Less than a 50 employees, single small geographical area site, low pollution/hazard potential 1-2 person days on site
(no hazardous substances handled or emissions to air/land/water), simple manufacturing/
processing operations

Audit Outputs
50-500 employees, larger single geographical site or more than one site, higher pollution/ 2-3 person days on site
hazard potential (e.g. handling hazardous substances, on-site waste treatment activities)

500+employees, large single geographical site or multiple sites, high inherent pollution- hazard 4-6 person days on site
potential (e.g. handling highly hazardous substances on site), complex processing operations

Glossary
However, the information provided in the table above is • language skills;
intended as an indication only. The actual length of audit
• ethnic/national background reflecting that of the
should be agreed between the audit requestor and the
workforce;
auditing company.
Appendices

• reputation;
3.2.3 Audit team • integrity;
• commitment to improving environmental compliance and
The audit should be conducted by a competent environmental performance.
auditor, who may be self-employed or be employed by a
commercial organisation, NGO or industry body3. Auditors To prevent any conflict of interest, the auditor must not
and auditing bodies should be selected based on: have any connection with the employment site. It would be
recommended that an audit be performed by two auditors,
• a udit training and skills; particularly if the site is remote and/or there is the potential
• a udit experience; for safety/security issues to be associated with the audit.
• local and industry knowledge;

3. The GSCP has launched an Expert Working Group that works exclusively on auditor competence. Its role is to identify and gather best practice in that area in order to build
reference requirements for recognition of auditors and auditing bodies.

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Background and context review

Reference Environmental Audit Process & Methodology - november 2010

Risk Assessment System

3.3 Communicating the audit arrangements

Audit organisation

3.3.1 Information for the employment site / procedures (e.g. waste handling and disposal, spill
containment etc.);
The buying company and/or auditor should communicate / training records;
the following information to the employment site at least / details of permits, consents and licences (or
2 weeks before the audit. This should be communicated in documented exemptions where applicable) for:
writing and in the relevant local language. - water abstraction;
Communicating the audit arrangements
Audit Request

• Confirmation of receipt of the Pre-Audit Employment Site - effluent wastewater discharges;

Profile and any further information required from the - storm water discharges;
employment site. - emissions to air;
- chemical and fuel storage;
• Identity of the audit requestor. - on-site waste management and storage; and
• Information about the audit requestor’s policies towards - off-site waste disposal information including contractor’s
environmental compliance and the requirements and code licences;
Preparation

of conducts against which the employment site is being / hazardous substances list/inventory;
audited. / safety data sheets for hazardous substances;
• Introduction of the audit team. / emission sources inventories (e.g. emissions to air, land
• The audit agenda including: and water);
/ inspection/service logs and inspection reports for
Audit Execution

/ timetable;
environmental-critical equipment e.g. abatement
/ topics to be covered.
Supplier preparation

equipment etc.;
• Key personnel invited to participate in the audit, including / spill/incident log and remedial steps taken including
but not limited to: correspondence with authorities regarding e.g. spills,
/ management; leaks, odour, noise etc.;
/ engineering/maintenance; / environmental emergency procedures;
/ environmental; / inventory (or similar) of air emission points;
Audit Outputs

/ manufacturing/operations; / air emission monitoring log/results;

/ purchasing/procurement. / greenhouse gas data (use, release etc.);
/ energy use data;
• Information which the employment site should communicate
to relevant workers before the audit covering the audit / water sources (e.g. from abstraction borehole), uses
process, purpose, ground-rules for worker interviews, (e.g. process water, cooling etc.) and consumption data;
confidentiality of worker interviews. / employment site drainage plan;
Glossary

• List of documents (where applicable) that the employment / wastewater monitoring log/results;
site will need to make available to the audit team on the / waste documentation including manifests for off site
day of the audit, including: disposal, waste contractor licences and permits etc.;
/ management structure (e.g. organogram); / site audits of waste contractors;
Appendices

/ environmental committee meeting minutes; / bulk tank inventory (including contents, capacity etc.);
/ employee handbooks; / bund/secondary containment inventory;
/ previous environmental reports/Corrective Action Plan / tank/bund inspection logs/reports;
Report; / tank/bund integrity testing logs/reports;
/ employment site layout/floor plan; / asbestos survey reports, asbestos register, management
/ maps of the surrounding area, if available; plan and inspection reports;
/ information on nearby protected habitats (e.g. local / ozone depleting substances (ODS) inventory and inspection
nature reserves) including distance from site, if available; logs/reports;
/ information on the site geology and hydrogeology, if / polychlorinated biphenyls (PCBs) inventory and inspection
available; logs/reports;
/ company environmental policies; / ionizing radiation sources registration, disposal records
and inspection records;
/ government/agency Inspection Reports, e.g. environ‐
mental compliance, etc.;

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Background and context review
Reference Environmental Audit Process & Methodology - november 2010

Risk Assessment System

/ intrusive soil and groundwater investigation reports / communications with environmental regulating agencies/
and on-going monitoring requirements; authorities relating to environmental violations and

Audit organisation
/ major incident risk assessments and/or incident reports; pollution incidents (air, water, effluent, wastes, odour
and noise).
/ nuisance/complaints log;
/ notices of violation or fines from a regulating agency;

Communicating the audit arrangements

Audit Request
3.3.2 Sample Audit Agenda

Client Name Audit Date(s) Job N o

Employment site name and address

Preparation
Day 1 – date

Duration Auditor 1 Auditor 2

Morning Opening meeting & plant tour

Site tour: Site tour:

Audit Execution
• Internal production areas • Internal production areas
• Internal areas including boiler room, • Internal areas including boiler room,

Supplier preparation
compressor house, waste handling compressor house, waste handling
areas etc. areas etc.
• External areas (e.g. waste storage, • External areas (e.g. waste storage,
wastewater treatment plant) wastewater treatment plant)
and including site perimeter survey and including site perimeter survey
• Worker interviews • Worker interviews

Audit Outputs
Lunch time Lunch break/Auditors’ meeting

Afternoon One-to-one Interviews: Document review

• Environmental manager
• Engineering/maintenance manager
and or department personnel

Glossary
• Manufacturing/operations manager
• Procurement/purchasing personnel
• Representatives from contractors
on-site
Appendices

Clarification/Auditor meeting

Closing meeting/End of the audit

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introduction

Background and context review

Reference Environmental Audit Process & Methodology - november 2010

Risk Assessment System

3.4 Supplier preparation

Audit organisation

Employment site management should ensure that: 3.4.1 Information for workers
• all documentation is available on the day of the audit.
This includes information and documents that are usually Clear information about the audit should be communicated
stored at another location (e.g. a central office where by the employment site to applicable workers explaining the
environmental data or records are held such as waste purpose of the visit and the process. This information should
be available in the principal languages spoken by workers
Communicating the audit arrangements

documentation or monitoring results);

Audit Request

and should include:

• relevant personnel are at the employment site;
• purpose and scope of the audit;
• supervisors and managers are instructed to allow
unobstructed access to auditors. • introduction to the auditors and their role (emphasising
they are independent and external);
• process including confidentiality of worker interviews
(where required);
Preparation

• contact details for the auditor and for any whistle-blowing

facility supported by the audit requestor.
Supplier preparation
Audit Execution

Sample communication

On (insert date), representatives from (insert audit The visit will primarily consist of meetings with management,
company) will be visiting (insert employment site name) to a facility inspection, and document reviews.
assess environmental performance and compliance. The
A limited number of worker interviews with identified
representatives will be looking at the following areas:
workers who have specific roles and responsibilities
• environmental management systems; for managing environmental issues or environmental
Audit Outputs

compliance will also be undertaken. Worker interviews may

• energy use and Greenhouse Gas (GHG) emissions;
also be undertaken to establish the level of awareness of
• water use; environmental issues across the facility and to help identify
any issues or good practice on-site. The interviews are strictly
• wastewater effluent;
confidential and the identity of workers who participate will
• emissions to air (including ozone depleting substances (ODS); remain anonymous.
• waste management; You may be asked questions by the representatives
Glossary

from (insert audit company) as they walk around (insert

• pollution prevention/hazardous and potentially hazardous employment site name). The selection of workers is based
substances; on a representative sample and you are not required to
• major incident management; participate in interviews.
Appendices

• contaminated land/soil and groundwater pollution prevention; If you would like to get in touch with the representatives
from (insert audit company) to discuss the audit or any other
• land use and biodiversity; issues, please do not hesitate to get in contact using the
• nuisance. contact details below:
(Insert contact details of audit company)

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Opening meeting
Reference Environmental Audit Process & Methodology - november 2010

Risk Assessment System

Employment site tour
4. Audit Execution
The audit should include the following: • audit team pre-closing meeting;

Interviews
• opening meeting; • closing meeting, including summary of findings;
• employment site tour (and perimeter survey) – this may • agreement of findings.

Audit Request
require visits to separate geographical locations if these
This chapter sets out best practice for each step of the audit.

Document review
are part of the activities operated by the employment site
relevant to the products being produced for the buying As a general principle, the conduct of the audit team at all
company requesting the audit; times must be in the best interest of the workers.
• management and worker interviews;

Preparation
• document review;

Alert notifications
4.1 Opening meeting • establish the audit agenda and indicate the personnel
required at each stage of the inspection;
The opening meeting must be conducted in the language

Audit Execution
• review the information provided in the pre-audit
spoken by management. It should be attended by relevant

Audit team pre-closing meeting

employment site profile (including previous corrective
people including:
action report and follow-up actions);
• environmental Manager (or similar);
• provide the employment site management with the list
• senior site management; of the documents to be reviewed during the audit [see
section 3.3.1 Information for the Employment Site];
• managers responsible for key functions, e.g. Production
Manager, Maintenance Manager. • confirm key workers and personnel who have responsibilities

Audit Outputs
for environmental issues and their availability for interview/
This should be formally presented in a format agreed with the
participation during the course of the audit;
audit requestor to ensure the audit requestor’s perspective
is clearly communicated in an appropriate tone. • c onfirm any special arrangements/precautions required for

Closing meeting
the employment site tour;
In the opening meeting, the audit team should:
• confirm permission to take photographs.
• introduce the audit team;

Glossary
Agree process for communicating issues as they arise during
• explain the purpose and scope of the audit, including:
the audit. It is best practice to communicate issues as they
/ potential benefits to the employment site (opportunity arise to build consensus around findings and corrective
for management to identify and manage risk, opportunity actions and allow management to:
to engage in continuous improvement, opportunity
to meet customer needs, opportunity to save money • provide additional evidence where necessary;
Appendices

through environmental improvement, improved • address issues immediately;

compliance with environmental legislation etc.);
• confirm the importance of attendance at the closing
/ clarify that the purpose of an audit is continuous
meeting and ensure that all key personnel can attend;
improvement;
/ the standard against which the audit will be conducted • provide an opportunity for questions and to address
(the GSCP Environmental Reference Requirements and concerns;
customer requirements, applicable local, national and • confirm the process for presenting audit findings to the
international laws, whichever are the more stringent); employment site and confirm how audit findings will be
• explain that the minimum expectation on the employment followed-up.
site in relation to the audit is transparency;
• outline the audit process;

Global Social Compliance Programme_11

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Opening meeting

Reference Environmental Audit Process & Methodology - november 2010

Employment site tour
Risk Assessment System

4.2 Employment site tour

4.2.1 Process • identify potential sources and impacts to the environment;
• note other physically observable evidence that relate to
The purpose of the employment site tour is to enable other areas of the standards;
the audit team to observe the current practices in all
Interviews

areas of the employment site and to form a view of how • identify and confirm off-site contractors or suppliers that
these practices measure up to the GSCP Environmental provide environmental services to the employment site
Audit Request

Reference Requirements, applicable legal and regulatory (e.g. waste contractors, maintenance service providers of
requirements and other applicable requirements, e.g. environment-related equipment);
Document review

customer requirements/policies. The findings from the tour • observe management systems and practices, including the
are triangulated with evidence from management and key relationship and interactions between management and
personnel interviews and document review. workers.
As a general principle, the auditor should be able to visit all The team should raise issues as they arise during the
the areas of the employment site and should set the pace
Preparation

employment site tour, giving managers the opportunity

of the tour. However, in some cases, employment sites
Alert notifications

to seek clarification, respond, and provide explanations or

may prohibit visitors from walking unaccompanied through further evidence.
employment site production areas or forbid photography for
reasons of safety or commercial confidentiality. The auditor The auditors should look to identify areas where there
should note restrictions on access or photography in the is high potential for pollution or other environmental
audit report, and if restrictions seem unreasonable should incidents. The audit should consider routine site operations
Audit Execution

escalate according to the audit requestor’s policy. and activities, but also non-routine operations and activities,
Audit team pre-closing meeting

e.g. maintenance, cleaning and operations and activities

Auditors should make every effort to ensure production is not undertaken on-site by contractors.
disrupted during the employment site tour, whilst ensuring
that they are able to view the production area during busy
production periods. It should be possible to move around 4.2.2 Perimeter survey
the site without delaying or halting production.
A perimeter survey should be undertaken, where feasible, to
Audit Outputs

The ability for management to continue production at the

provide supplementary information about the employment
site during a visit is crucial to gaining an accurate idea of
site and its local context and to identify specific risk issues to
current practices and to securing management co-operation
the environment and/or the surrounding areas.
for the remainder of the visit. Further, the safety of the
auditor and the persons accompanying them on the site
Closing meeting

The perimeter survey should focus on:

tour is of paramount importance. Auditors should keep this
in mind during the site tour. In order to achieve this, the • the general nature of the surrounding environment (e.g.
auditor should for example: rural, industrial, residential neighbourhood, business
Glossary

district, etc.);
• ask that they be accompanied by only one or two people;
usually the site or environmental manager, or whoever is • the nature of immediate neighbouring facilities (e.g.
best placed to answer questions on environmental issues manufacturing, waste treatment/disposal, etc.);
(e.g. facility maintenance or operations representatives); • areas of potential off-site impact to the employment site
Appendices

• be aware of site traffic and stay on dedicated pedestrian (e.g. pollution or contamination associated with off-site
routes (wherever possible); bulk storage tanks, off-site waste storage areas, etc.);

• avoid walking where workers are trying to move or transport • areas of potential impact from on-site activities (e.g.
product from one area to another. distressed vegetation, the nature and quality of external
surface areas etc.);
The audit team should walk around the employment site,
external areas and site perimeter (where feasible), internal • other facilities located on the employment site property
production areas, raw material/chemical and waste storage (e.g. waste water treatment plants, electricity substations
areas, bulk storage areas, boiler rooms, compressor houses etc.);
and other applicable areas with managers in order to: • other production units within the employment site property,
• understand the work done at the employment site; which are not part of the scope of the audit.

• evaluate environmental practices;

12_Global Social Compliance Programme

 introduction
Opening meeting
Reference Environmental Audit Process & Methodology - november 2010

Employment site tour

Risk Assessment System

4.3 Interviews
Interviews with managers and a limited number of worker Location:
interviews with key workers who have specific roles and
• formal interviews should take place in a quiet, private area
responsibilities for managing environmental issues or
away from management offices with no representatives of

Interviews
environmental compliance will be undertaken. Worker
management present;
interviews may also be undertaken to establish the level
of awareness of environmental issues across the facility • informal interviews may also take place during the physical

Audit Request
and to help identify any issues or good practice on-site. tour of the employment site, at lunch time or in breaks;
The interviews are strictly confidential and the identity of

Document review
• where possible, worker interviews should be held in
workers who participate will remain anonymous.
the interviewee’s language, where this is not possible
worker interviews may be conducted through a translator.
4.3.1 Worker interviews Translators must be independent of employment site
management and must speak the language concerned.
Points raised by workers should be fed back as early as

Preparation
Protection of workers:

Alert notifications
possible to members of the team carrying out management
interviews or document review to facilitate verification. • auditors should ensure that problems raised by workers
are discussed with management in a non-attributable
Audit team members carrying out worker interviews must way. Auditors must ensure that the comments they report
have the skills to make workers feel at ease. It is best practice cannot be traced back to an individual worker;
to use interviewing techniques to encourage interviewees to

Audit Execution
identify the issues of most importance to them. In any case, • auditors/worker interviewers should leave a contact

Audit team pre-closing meeting

the interviewer should use appropriate body language (e.g. telephone number, preferably their mobile number
avoid sitting behind a desk, make regular eye contact, smile, and their local office phone number, with all workers
etc.) interviewed so that workers can alert the worker
interviewer if there are reprisals or intimidation;
Selection:
• the auditor should keep a confidential note of who is being
• the interviewer should aim to talk to a number relevant interviewed.
workers, taking into account:

Audit Outputs
/ different departments, including workers associated Interview structure:
with managing waste, undertaking environmental • introduction: The audit team should introduce themselves
monitoring as well as production workers; and communicate the purpose of the audit. They should

Closing meeting
/ health & safety representatives/personnel, where assure interviewees that all information shared during the
appropriate; interview will remain unattributed;
/ environmental committee representative(s), if applicable; • confidentiality: No manager or representative of the

Glossary
/ new employees/trainees (to evaluate training quality); employment site, apart from the workers concerned,
/ employees from different shifts. should be present during any worker interview.
Appendices

Global Social Compliance Programme_13

introduction

Opening meeting

Reference Environmental Audit Process & Methodology - november 2010

Employment site tour
Risk Assessment System

4.4 Document review

In countries where there are data protection requirements obtain the written permission of workers to view personnel
(e.g. all EU countries), auditors should respect data files during any interviews (e.g. when reviewing training
protection requirements during reviews of environmentally- records etc.). Workers should be assured that they are able
Interviews

related documents. Auditors should also, where applicable, to refuse permission to view their files if they so wish.
Audit Request

Document review

Example data protection consent form

In order to administer your employment, your employer about environmental standards. As part of this review,
collects and uses certain personal information (such as (Insert Audit Company Name) may need access to your
your contact details, roles and responsibilities and training personnel file.
records/attendance). This information constitutes your
You have confirmed that you are happy for (Insert Audit
Preparation

personnel file.
Company Name) to have access to your personnel file for
Alert notifications

(Insert Audit Company Name) has been engaged to review

the purposes of the review.
the environmental practices of your employer for the
purposes of ensuring compliance with the (Insert Code(s)) Please sign below to give your permission.
Audit Execution

4.4.1 Document sampling • information on the site geology and hydrogeology, if

Audit team pre-closing meeting

available;
The documentation requested by the auditor should be • company environmental policies;
available on-site, including, but not limited to, applicable
licences/permits, internal and external reports, emission • government/agency Inspection Reports, e.g. environmental
sources inventories, spill or incident release records and compliance, etc.;
notifications, maintenance records, integrity testing records,
Audit Outputs

• procedures (e.g. waste handling and disposal, spill

waste documentation, environmental committee meetings containment etc.);
or minimisation projects, monitoring data and training
materials. Auditors should review documentation from • training records;
the previous 2 years (e.g. monitoring data, maintenance
Closing meeting

• details of permits, consents and licences (or documented

records), however, older documentation may reasonably be exemptions where applicable) for:
requested where it is necessary to demonstrate compliance.
If records for the previous 2 years are not available, the / water abstraction;
Glossary

employment site should explain why this is the case. For / effluent wastewater discharges;
example, the employment site has been operational for less / storm water discharges;
than 2 years. / emissions to air;
The auditor should go through a comprehensive document / chemical and fuel storage;
Appendices

trail including the following (this is not an exhaustive list): /o  n-site waste management and storage; and
• management structure (e.g. organogram); / off-site waste disposal information including contractor’s
• environmental committee meeting minutes; licences;

• employee handbooks; • hazardous substances list/inventory;

•p
 revious environmental reports/Corrective Action Plan • safety data sheets for hazardous substances;
Report; • emission sources inventories (e.g. emissions to air, land and
• employment site layout/floor plan; water);

• maps of the surrounding area, if available; • inspection/service logs and inspection reports for environ‐
mental-critical equipment e.g. abatement equipment etc.;
• process diagrams;
• spill/incident log and remedial steps taken including
• information on nearby protected habitats (e.g. local nature correspondence with authorities regarding e.g. spills,
reserves) including distance from site, if available; leaks, odour, noise etc.;

14_Global Social Compliance Programme

 introduction
Opening meeting
Reference Environmental Audit Process & Methodology - november 2010

Employment site tour

Risk Assessment System

• environmental emergency procedures; • ionizing radiation sources registration, disposal records
and inspection records;
• inventory (or similar) of air emission points;
• intrusive soil and groundwater investigation reports and
• air emission monitoring log/results; on-going monitoring requirements;
• greenhouse gas data (use, release etc.);

Interviews
• major incident risk assessments and/or incident reports;
• energy use data; • nuisance/complaints log;
• water sources (e.g. from abstraction borehole), uses (e.g. • notices of violation or fines from a regulating agency;

Audit Request
process water, cooling etc.) and consumption data;

Document review
• communications with environmental regulating agencies/
• employment site drainage plan; authorities relating to environmental violations and pollution
• wastewater monitoring log/results; incidents (air, water, effluent, wastes, odour and noise).
Particular emphasis should be placed on evidence that there is
• waste documentation including manifests for offsite
a systematic approach to managing all aspects of the relevant
disposal, waste contractor licences and permits etc.;
codes or requirements.

Preparation
Alert notifications
• site audits of waste contractors;
• bulk tank inventory (including contents, capacity etc.); 4.4.2 Document inconsistencies
• bund/secondary containment inventory;
Inconsistencies between different types of documents
• tank/bund inspection logs/reports; and worker testimony may be considered a critical non-

Audit Execution
compliance, depending on the potential environmental
• tank/bund integrity testing logs/reports;

Audit team pre-closing meeting

issues and risks presented by those inconsistencies. Where
• asbestos survey reports, asbestos register, management deemed to be a critical non-compliance, it should be raised
plan and inspection reports; appropriately with employment site management and as per
the Alert Notification process.
• ozone depleting substances (ODS) inventory and inspection
logs/reports; If a non-compliance related to permit or licence requirements/
conditions is identified, the audit team should identify the

Audit Outputs
• polychlorinated biphenyls (PCBs) inventory and inspection context of the issue, and its frequency, and the department(s)
logs/reports; concerned both at the closing meeting and in the audit report.

Closing meeting
4.5 Alert notifications

Glossary
Where a ‘critical’ non-compliance (whether a non-compliance If an auditor believes they might be at risk as a result of
with legal requirements or the GSCP Environmental communicating a critical non-compliance, the audit team
Reference Requirements) is identified, the auditor should, should wait until it is removed from that situation before
wherever possible, inform the audit requestor as soon as issuing the alert notification.
possible. If the audit requestor is on site, the auditor should
Examples of non-compliances can be found in paragraph
Appendices

communicate the critical non-compliance immediately. This

“4.6.1 Non-compliances, Observations and Good Practices
will enable the audit requestor and the employment site to
Evaluation”
work together to plan an appropriate and timely resolution
to the issue. A reference alert notification is available in Appendix 4.

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Opening meeting

Reference Environmental Audit Process & Methodology - november 2010

Employment site tour
Risk Assessment System

4.6 Audit team pre-closing meeting

The audit team should meet before the closing meeting The reference Summary of Findings and Corrective Actions
to discuss the findings of the audit (interviews, document includes:
checks, employment site tour) and agree the performance
Interviews

• audit findings: Confirmation of performance level in

level demonstrated by the site in relation to each of the 11
relation to each of the 11 Performance Areas, summary of
defined Performance Areas and identify inconsistencies,
non-compliances, good practice, and evidence found;
non-compliances, observations, and good practice. The
Audit Request

analysis of evidence gathered is a pre-requisite to the closing • classification of non-compliances;

Document review

meeting. It must be completed even if the auditor is alone at

• reference to the applicable code of conduct and/or law
the employment site.
which has been contravened;
The audit team should prepare for the closing meeting by
• recommended corrective actions: Auditors suggestion on
identifying and agreeing:
how the audit findings can be resolved;
• the performance level demonstrated by the site in relation
• person/party responsible for corrective action;
Alert notifications
Preparation

to each of the 11 defined Performance Areas;

• verification method:
• level 1 Non-compliances identified including:
/ a desk-based follow up may be used to verify corrective
/ t heir status/severity (critical, major, minor);
actions for minor non-compliances but provide less
/ s upporting evidence; assurance than a follow-up audit. Desk-based verification
/ r ecommended corrective actions, how these can be should check corrective actions through photos, copies
Audit Execution

Audit team pre-closing meeting

verified, and a suggested timeframe for completion; of certificates/licences/permits, monitoring data, etc.
submitted by the employment site. Desk-based follow-
• systematic problems and issues from one-off, isolated,
up cannot be used where actions need to be verified
non-systematic issues;
through worker testimony;
• the root cause of problems, where possible; / follow-up audit are recommended for critical or major
• good practice examples; non-compliances or when corrective actions can be
evaluated only through interviews and extensive
• a prioritisation of issues;
Audit Outputs

documentation reviews [see section 5.4 for guidance

• any requests for additional information or evidence. on conducting follow-up audits];
• timescale for completion: The amount of time required for
A note on Corrective Actions
the issue to be closed. The time allocated for corrective
Audit requestors (companies and/or individuals) may take a actions to be completed should be appropriate, realistic
Closing meeting

number of different approaches with respect to corrective and timely.

actions, for example:
The Summary of Findings and Corrective Actions should:
Glossary

• require auditors solely to identify corrective actions and

• be clearly described and presented in both English and the
require the employment site to develop the corrective
language spoken by the employment site management;
action plan following the audit or
• be distributed as follows:
• require auditors to identify evidence-based findings and
Appendices

work with the employment site to develop a corrective / one original, signed copy for the employment site
action plan or manager;
/ a second original, signed copy retained by the auditor
• require auditors to identify evidence-based findings,
together with other audit documentation;
develop the appropriate corrective action and agree with
the employment site on their follow-up. / a hard or soft copy to the audit requestor.

However, reference is made here to both ‘findings

and corrective actions’ on the understanding that the 4.6.1 Confirmation of performance level
identification of corrective actions may be required. and evaluation of non-compliances,
The reference Summary of Findings and Corrective Actions
observations and good practices
(Appendix 6) has been designed to provide a structure to
Auditors should confirm the level that the employment site
the audit team’s findings and help the audit team develop a
demonstrates in relation to each of the 11 Performance Areas
corrective action plan and structure a closing meeting.
and the evidence upon which this is based (an employment
site can demonstrate different levels of performance against
different Performance Areas).

16_Global Social Compliance Programme

 introduction
Opening meeting
Reference Environmental Audit Process & Methodology - november 2010

Employment site tour

Risk Assessment System

For the employment site to be identified as meeting a Follow-up audits are recommended for critical or major non-
particular performance level in relation to a Performance compliances or when corrective actions can be evaluated only
Area, it must be meeting all of the individual requirements in through interviews and extensive documentation reviews [see
that (and any preceding) performance level. For example, a section 5.4 for guidance on conducting follow-up audits].
site cannot achieve performance level 2 unless it is meeting
4.6.1.1 Categorisation examples

Interviews
all of the level 1 and level 2 requirements. An employment
site can be fully meeting a particular performance level and The below provides guidance on how to categorise different
be demonstrating that it meets some of the requirements of issues as minor, major or critical non-compliances. The list
the next performance level.

Audit Request
gathers examples and is not intended to be exhaustive. It

Document review
Auditors should classify non-compliances against Level 1 gives an indication of how various issues should be considered
Requirements and observations and examples of good practice in light of the reference guidelines and the reference code
against all performance level. and taking into account the potential environmental impact
of the issues identified and the regulatory regime of the
Should any critical or major legal non-compliance be country. These examples are for illustration only; auditors
identified in relation to a particular Performance Area, then should still use their discretion when classifying non-
the employment site cannot be considered as meeting

Alert notifications

Preparation
compliances.
the basic requirements associated with Level 1 for that
Performance Area. Minor

In relation to Level 1 Requirements, Auditors should record • basic environmental management structure and defined
non-compliances, whether they be non-compliances management responsibilities are in place, however, this is
with legal requirements or non-compliances with the not documented;

Audit Execution
Environmental Framework Requirements themselves.

Audit team pre-closing meeting

• site has identified and is managing its potentially significant
Non-compliances should be categorised as: aspects and impacts but has not documented this process/
the results;
• minor non-compliance;
• relevant inventory/register established in relation to a
• major non-compliance; or particular Performance Area, but not actively maintained;
• critical non-compliance. • an occasional or isolated compliance issue e.g. missing
records/documentation in relation to permit/consent/

Audit Outputs
The auditor should record in the Audit Report (Appendix 5)
whether a non-compliance identified is a non-compliance licence requirements;
with specific legal requirements. • the site has a mechanism to remain up to date with appli-
If no non-compliances are identified, then the Employment cable local legal requirements, but has not documented
Site is considered to have met the Level 1 Requirements this process;

Closing meeting
for that Particular Performance Area. However, should any • an issue which presents a risk to the environment (low risk)
critical or major non-compliances be identified in relation (either on-site or the surrounding areas);

Glossary
to a particular Performance Area, then the employment site
cannot be considered as meeting the basic requirements • site has a procedure to ensure that external third parties
associated with Level 1 for that Performance Area. If only utilised by the site for environmental matters (e.g. waste
minor non-compliances are identified, then it will be removal/disposal) are appropriately licensed, but has not
judgement decision by the Auditor (and possibly by the Audit documented this process;
Appendices

Requestor) as to whether the Employment Site is considered • occasional or isolated instances of missing monitoring/
to have met the Requirements of Level 1 in relation to that performance data (that is not a legal requirement).
particular Performance Area.
Major
Non-compliances and observations should be classified
according to: • basic management structure/defined management
responsibilities not in place, either in relation to overall
• the frequency of the problem or whether the issue is an environmental management or particular Performance
isolated occurrence; Area;
• the potential severity of the problem; • site has identified that it has potentially significant
• the probability of recurrence of the problem. environmental aspects/impacts, but has not acted on this
information;
The auditor must be able to justify his/her classification with
detailed evidence. • site is not aware of its legal requirements in relation to a
particular performance area;

Global Social Compliance Programme_17

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Opening meeting

Reference Environmental Audit Process & Methodology - november 2010

Employment site tour
Risk Assessment System

• site has no mechanism for remaining up to date with • non-operation of critical abatement equipment e.g. air
applicable legal requirements; emission scrubber, incineration unit etc.;
• site not aware of relevant permit/ licence/ consent/exemption • evidence of the deliberate provision of false information
requirements; to auditors or regulators so as to disguise non-compliances
with permit/licence/consent requirements;
Interviews

• breaches of legislation or permit/licence/consent

requirements which represents risk of moderate harm to • performance or monitoring data manipulated or misreported
the environment e.g. exceedance of wastewater discharge to intentionally mislead regulators;
limits, exceedance of air emission limit concentration etc.;
Audit Request

• a major non-compliance from a previous audit that has not

Document review

• a systemic breach or violation of a legal requirement; been addressed or for which no significant improvement
has been made by the time of a follow up audit and which
• a breach of a legal requirement or environmental permit/
has increased the level of environmental risk, e.g. of
licence/consent which is considered likely to attract
causing incidents;
regulator intervention;
• site knowingly utilises illegal/unlicensed external third
• site has not confirmed that all external third parties utilised
parties in relation to environmental matters (e.g. waste
Alert notifications
Preparation

by the site for environmental matters (e.g. waste removal/

removal/disposal);
disposal) are appropriately licensed;
• site has not provided identified and/or provided training
• relevant inventory/register not established in relation to a
to employees on environmental matters which represent a
particular Performance Area;
serious or significant impact to the environment.
• consumption/generation data not collected in relation to
Critical non-compliances should trigger an alert notification
Audit Execution

a particular Performance Area that is relevant to the site.

Audit team pre-closing meeting

[see section 4.5].

Critical
An Observation
• an environmental aspect which represents imminent risk
• a possible issue which could develop into a non-compliance
of serious or significant impact to the environment (e.g.
if action is not taken by the Employment Site (i.e. a potential
major damage to a local ecosystem, closure of a potable
non-compliance);
water abstraction point, known on-site or off-site impact
to soil, groundwater or surface water); • an issue, on which the auditor has some evidence to indicate
Audit Outputs

that it may be present, but is not confirmed by more than

• site has identified that permit/licence/consent/exemption
one data point;
required, but has not obtained it;
• an opportunity for improvement e.g. how the employment
• relevant inventory/register not established in relation to
site can meet the requirements of the next performance level.
a particular Performance Area, which has the potential
Closing meeting

to result in non-compliance with permit/licence/consent Good Practice

requirements or which results in mis-management of
Glossary

A positive, innovative or novel approach, technology or a

environmental matters with the potential for significant
process to managing environmental issues in relation to a
impact to the environment;
particular Performance Area that improves performance
• site currently under threat of prosecution, fine and/or over and above the standard.
enforcement in relation to an environmental issue;
Level 2 and Level 3 findings
Appendices

• an attempt to pervert the course of the audit through

fraud, coercion, deception or interference; Given that the GSCP Environmental Reference Requirements
at levels 2 and 3 are intended to drive performance
• a systemic violation of a legal requirement that has improvement. As such, the Auditor should record only
attracted (or could likely attract) regulator intervention whether the Employment Site has met or not met a particular
(e.g. continued illegal disposal of waste materials, either Requirement, together with observations and examples of
on-site or off-site); good practice, if applicable. Where the auditor identifies
• auditors denied access or obstructed from conducted from that a Requirement is not met, they should provide a short
conducting a proper audit; description as to why.

18_Global Social Compliance Programme

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Audit report
Reference Environmental Audit Process & Methodology - november 2010

Supplementary audit information

Risk Assessment System

4.7 Closing meeting
The purpose of the closing meeting is to go through the • answer questions that management have;
findings, agree them and agree the corrective action
• explain when the full report will be completed and who it
plan which sets out areas for improvement, actions and
timeframes. Corrective actions should focus on long term will be sent to;
sustainable solutions which take account of the root cause of • get sign-off on the Summary of Findings and Corrective

Information management
any problem. This meeting should involve all those attending Actions by both auditor and employment site:

Audit Request
the opening meeting and should:
/w
 hen agreed with the audit requestor, a copy of the
• reconfirm the purpose of the assessment; corrective action plan should be left with management;
• confirm the performance level for each of the 11 Performance / t he corrective actions should include a timeframe for
Areas; completion and the type of verification needed;
• recognise good practices; • if the Summary of Findings and Corrective Actions is
not agreed, the auditor should leave a copy with the

Preparation
• agree any non-compliances;

Audit follow-up
employment site and report disputed points to the audit
• record non-compliances which can be corrected immediately; requestor, copying the employment site.

Audit Execution
5. Audit Outputs
5.1 Audit report

Audit Outputs
The context, findings, issues and actions, where applicable, • for each non-compliance or observation, provide a:
against each of the 11 Performance Areas should be reported / description of the non-compliance or observation and
to the audit requestor. The report should be available its frequency;
in English to ensure that it can be shared with various
/ evidence found to substantiate it;
stakeholders, as well as in the language of the management
wherever this is possible. The report should be delivered to / classification to applicable law, code of conduct, etc.
the audit requestor within 10 business days of the audit. The report must not include any information that could

Glossary
The report should include: be used to identify specific workers – such as names, ID
numbers, job descriptions and/or work location.
• a summary of the auditors’ evaluation of the employment
site’s performance against each of the 11 Performance The report should include photos4 of the employment site
Areas; such as:
Appendices

• identified non-compliances which indicate that the • outside general overview;

employment site is not meeting Level 1 of the GSCP • inside general overview;
Environmental Reference Requirements;
• key activities and processes that have potential environ‐
• observations and good practices. mental impact;
For each environmental Performance Area, the report • waste handling and storage areas;
should:
• hazardous substance storage areas;
• describe the current situation including which of the
GSCP Environmental Reference Requirements the site is • areas of potential impact to soil and groundwater including
currently meeting; staining and distressed vegetation;
• provide evidence and information to substantiate the • bulk storage tanks and secondary containment;
findings;

4. Photographs should only be taken with the permission of the employment site as they may contain or reveal confidential information.

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introduction

Audit report

Reference Environmental Audit Process & Methodology - november 2010

Supplementary audit information
Risk Assessment System

• wastewater treatment areas; Unless agreed by all parties in writing, the audit organisation
will not distribute the report to any entities except the audit
• abatement equipment;
requestor. However, the audit requestor should share the
• good practices where these can be photographed; report with the employment site/customer/supplier as soon
as possible in order to facilitate co-operation on continuous
• non-compliances where these can be photographed.
improvement.
A reference audit report is available in Appendix 5.
Audit Request

Information management

5.2 Supplementary audit information

Auditors may feel the need to separately report to the audit • concerns about the possibility of falsified records.
requestor in the event that, for example, the auditor has:
The process for reporting such information should be agreed
• information that is too sensitive for the audit report itself; between the audit requestor and the auditor in advance of
Preparation

the audit.
• concerns which cannot be substantiated through evidence
and/or interviews; A template for reporting additional information is available
Audit follow-up

in Appendix 7, Reference Environmental Supplementary

• commentary/insight on the attitude of management
Audit Information.
towards the non-compliances or where management was
obstructive to the audit process;
Audit Execution

5.3 Information management

Within 10 days of the completion of each audit, the auditor The auditor or audit organisation should:
should provide the following documents to the audit
• be available after the audit to further clarify or explain
Audit Outputs

requestor:
decisions and ratings to the employment site and/or audit
• the Pre-Audit Employment Site Profile; requestor as needed;
• the completed audit report, including photographs; • have an appeals procedure should the employment site or
audit requestor challenge one of the findings and in case of
• summary of findings (and corrective actions, if applicable);
any complaint by the employment site against the auditor.
• supplementary audit information, where applicable;
Glossary

• copies of any alert notifications that were issued during the

audit.
Appendices

5.3.1 Audit records

All documents (unless they are “business confidential”), hand • environmental licences and permits;
written notes, signed Summary of Findings and Corrective
• surveys (e.g. asbestos surveys);
Actions and audit report should be retained by the auditor
for reference for at least five years. • key environmental monitoring results;
It is recommended that the auditor retain copies of at least • communications or notices of violations issued by
the following documents assuming that this has been agreed regulatory authorities;
between the audit requestor and the employment site:
• evidence relating to non-compliances, wherever possible.
• official documents on legal status of the company (business
If copying facilities are not available, auditors should
licence);
photograph these documents.
• insurance policies/certificates (relating to buildings and
Data and privacy laws in some countries prohibit copies
people);
being made of certain documents; in such cases, auditors
should respect these restrictions.

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Audit report
Reference Environmental Audit Process & Methodology - november 2010

Supplementary audit information

Risk Assessment System

5.4 Audit follow-up
Audit follow-up focuses on the corrective actions agreed Follow-up Audit Guidance:
during the audit and closing meeting, if applicable (i.e. the
• the audit should be carried out once the deadline for
identification of corrective actions was part of the audit
addressing all of the issues has passed;
scope).

Information management
• follow-up audits should generally take place within six
Where such corrective actions were agreed:
months of the date of the initial audit;

Audit Request
• the auditor will be responsible for verifying whether actions
• a follow-up report should be issued. This is an updated
have been taken and recording verification of actions;
version of the original report, with all new issues and
• for corrective actions where desk-based verification is updates to previous issues clearly highlighted;
adequate, the auditor will review evidence submitted [see / for all sections where non-compliances have previously
section 4.6]; been raised there should be a clear explanation of the
• where a follow-up audit is required, the length of time evidence reviewed, comments on applicability and

Audit follow-up

Preparation
taken at the follow-up should be related to the number effectiveness and whether the issue is now considered
and severity of issues to be verified; closed or remains open;
/ improvements should be mentioned even if the non-
Follow-up audits may be commissioned by the audit
compliances are not fully corrected;
requestor, typically in relation to critical or major non-
compliances identified in relation to Level 1 issues, and/ / if new non-compliances are found these should be
or when corrective actions can be evaluated only through recorded and marked as “new” and should be reported

Audit Execution
interviews and extensive documentation reviews. in as much detail as they would have been in the initial
report;
• a partial follow-up audit does not include a full review
/ a desk-based follow up may be used to verify corrective
but only focuses on the issues identified in the corrective
actions for minor non-compliances but provide
action plan;
less assurance than a follow-up audit. Desk-based
• a full follow-up audit should include a full review of all verification should check corrective actions through
areas of the standard audit process, including the complete photos, copies of certificates, invoices, submitted by
the employment site. Desk-based verification cannot

Audit Outputs
re-sampling of documents, conducting interviews and
the employment site tour. The auditor should focus on be used where actions need to be verified through
identifying changes which would address issues raised in worker testimony.
the initial report, but also investigate potential additional
issues.
Typically, a full follow-up audit would only be necessary
where the non-compliances identified in the initial audit

Glossary
indicated that an environmental management system
was not in place or that there were extensive/systematic
failings associated with the site’s existing environmental
management system.
Appendices

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Reference Environmental Audit Process & Methodology - november 2010

Risk Assessment System

Glossary
of terms
Audit Request

Corrective action plan

A
Preparation

Announced audit A plan of action drawn up at the end of an audit that records
what measures have to be taken and within what time limit
to remedy the non-compliance.
An audit which is undertaken on a specified date that is
chosen in agreement with the employment site.

E
Audit Execution

Audit requestor
Employment site
Generic term referring to any entity that has requested and
commissioned an audit, including the requesting entity’s An individual/specific production site, farm, winery, quarry,
customers (where known) where agreements allowing such mine, service site etc. (including where applicable selected
disclosure are in place. sub-contractors/homeworkers).
Audit Outputs

EMAS
C
Code of conduct The European Union (EU) Eco-Management and Audit Scheme
(EMAS), is a voluntary initiative designed to help companies
evaluate, report on and improve their environmental
A set of standards concerning environmental practices adopted
performance. Its aim is to recognise and reward those
by a company and applied to its suppliers, employment sites
organisations that go beyond minimum legal compliance and
and subcontractors.
Glossary

continuously improve their environmental performance. It is

a requirement of the scheme that participating organisations
Comply/compliance regularly produce a public environmental statement that
reports on their environmental performance.
To meet local environmental laws and regulations and/or the
Appendices

GSCP Environmental Reference Requirements, applicable codes

of conduct and international labour standards requirements.
EMS – Environmental Management System

A management system is a set of interrelated elements

Continuous improvement used to establish policy and objectives and to achieve those
objectives.
The recurring process of enhancing the environmental
management system in order to achieve improvements
in overall environmental performance consistent with an
Environmental audit
organisation’s environmental policy.
(hereafter referred to as ‘audit’)

Systematic, independent and documented process for

Corrective action obtaining evidence and evaluating it objectively to determine
the extent to which environmental standards criteria are met.
Measures taken to eliminate a non-compliance identified
during an audit.

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Reference Environmental Audit Process & Methodology - november 2010

Risk Assessment System

F I
First party audit Initial audit

An internal audit that an organisation performs on itself to The first audit undertaken on an employment site which
evaluate conformity with procedures or a defined standard, assesses compliance against a specific code of conduct, or is
for example an audit could solely be against regulatory requested by a specific customer.
requirements.

Audit Request
Follow-up audit M
An audit to assess the effectiveness of corrective actions, Management
undertaken to address issues from a previous audit. A follow-
up audit can be either a full or a partial follow-up audit (see People who identify and achieve organizational objectives
definitions below). through the deployment of appropriate resources. A

Preparation
manager can have responsibilities in one or more of five key
areas: managing activities; managing resources; managing
Full follow-up audit information; managing people; and managing him- or
herself at the same time as working within the context
An audit to assess the effectiveness of corrective actions,
of the organizational, political, and economic business
undertaken to address issues from a previous audit. The audit
environments.
should include a full review of all areas of the standard audit

Audit Execution
process, including the complete re-sampling of documents,
conducting interviews and the employment site tour.
P
Partial follow-up audit
G
An audit to assess the effectiveness of corrective actions,
Good practice undertaken to address issues from a previous audit. The

Audit Outputs
audit does not include a full review, but only focuses on the
A positive, innovative or novel approach, technology or a
issues identified in the corrective action plan.
process to managing environmental issues in relation to a
particular Performance Area that improves performance
over and above the standard.
R
Greenhouse gas intensity Re-audit

Glossary
The quantity of greenhouse gases emitted, for example, per A new audit which is performed on an employment site that
unit of production. This is normalised data (as opposed to has already been audited under the same code of conduct or
absolute data), which allows comparison of greenhouse by the same customer.
gas emissions even if there are increases or decreases in
Appendices

production.
S
Grey water
(also referred to as grey water or gray water) Second party audit

Wastewater, typically generated from domestic-style An external audit of one organisation (e.g. supplier of
activities, for example washing machines, showers, bathtubs, products or services) performed by another organisation
hand washing, and sinks, together with some industrial (typically a customer for those products or services) to
processes, which is recycled/re-used and put to a different evaluate conformity with procedures or a defined standard.
use, for example, use in toilet flushing, cleaning or irrigation.
The grey water may require some treatment (physical,
biological or chemical) to ensure that it is of sufficient quality
for the new use. Grey water must NOT be used as potable
(drinking) water.

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Reference Environmental Audit Process & Methodology - november 2010

Risk Assessment System

Semi-announced audit Third party audit

An audit which is undertaken on an un-specified date, An external audit of an organisation, conducted by an

scheduled within a set period (between 2 weeks and 2 independent party or body, to evaluate conformity with
months), which is agreed with the employment site. The procedures or a defined standard. The audit may, for
employment site will be informed that an audit will take place example, be on behalf of another organisation or be
during this period but will not be informed of the exact date. performed by a certification body to assess compliance with
the international management systems standard ISO14001.
Audit Request

Stakeholder

Any person, company, organisation or other party that is U

affected by the activity and/or operations of a company.
Unannounced audit
Subcontractor An audit carried out without prior warning to the
Preparation

employment site.
An individual or a group of individuals to whom a contractor
outsources the manufacture of a product or part-product.

Summary of findings and corrective actions

V
Verification
A summary document which provides information about all
Audit Execution

issues and other findings from an audit, as well as corrective Examination of claims made about the actual observance of
actions and time frames for completing these. code or standard provisions by suppliers or of claims made
about the activities that a company undertakes to give effect
Supplier to its code. Verification implies that participating companies
must have internal auditing or monitoring systems in place.
Any contract partner which supplies the retailer/brand with
goods or services.
W
Audit Outputs

T Worker

Target (environmental) A person working on an employment site, in any capacity.

A detailed performance requirement (quantified where

Glossary

possible and applicable to all or parts of the organisation),

that arises from the setting of environmental objectives and
which needs to be set and met in order to achieve those
objectives.
A specific task in the achievement of an environmental objec‐
Appendices

tive. Environmental targets must be stated in a measurable

and quantifiable manner.
ISO14001:2004
Targets can be based on absolute data or normalised data.

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GSCP Reference Environmental Self Assessment Questionnaire
Appendix 1
GSCP Reference

Risk Assessment System

Environmental
Self-Assessment

GSCP Reference Environmental Supplementary Audit Information

Questionnaire

Audit Request
GSCP Reference Environmental Pre-Audit Employment Site Profile
This tool forms part of the GSCP set of reference tools The self assessment reference tool below is structured in
designed to provide a common interpretation of local and accordance with the GSCP Draft Environmental Framework

Preparation
international environmental standards and requirements and Requirements but is not designed to be used as a self audit
environmental reference codes (if available and applicable). against these Requirements. Buying companies or suppliers may
The Environmental Reference Requirements reflect a tailor the reference self-assessment to their specific by adding
common understanding of good environmental practice and or removing questions to meet their specific requirements.
are applicable to all raw material processing, agricultural,
Companies should communicate the following to employment
manufacturing and logistics sites in the supply chain. The

Audit Execution
sites when requesting this information:
Environmental Reference Requirements provide a model

GSCP Reference Environmental Summary of Findings and Corrective Actions

for a site in the supply chain to demonstrate continuous • reason for the information request;
improvement in its environmental performance from basic
• how the risk assessment fits within the audit process;
compliance to leading-edge performance (across three
defined ‘levels’ for eleven different performance areas). • to whom to send the completed self assessment (or how to
upload the self assessment on to a database);
The reference tools on Environmental Audit Process and
Methodology are based on the GSCP Environmental • timeframe for completion;

Audit Outputs
Reference Requirements but can be adopted and tailored to
other codes of environmental practice. • process and timeframe for updating the self-assessment;

GSCP Reference Environmental Audit Checks

The self-assessment questionnaire can be used by: • confidentiality arrangements when sharing information
provided in this questionnaire.
• a buying company to risk assess suppliers/employment
sites (e.g. to provide a basis for the development of an Employment sites should be encouraged to answer the self
audit programme); assessment questionnaire in full and add commentary and/
or evidence against each point rather than just marking Yes

Glossary
• a supplier or employment sites as an aid to their own or No.
risk reviews and/or preparation for their own self audit
programmes; and
• an auditor to focus on site investigation on high risk areas.
Appendices
GSCP Reference Environmental Alert Notification

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GSCP Reference Environmental Self Assessment Questionnaire

Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire

Environmental Audit Process & Methodology Reference Tools - november 2010
Risk Assessment System

Reference Self-Assessment
Questionnaire
GSCP Reference Environmental Supplementary Audit Information

Company Overview
Audit Request

Name of company which owns the employment

site to be audited

Ownership type (e.g. joint venture, partnership,

GSCP Reference Environmental Pre-Audit Employment Site Profile

corporation, foreign investment, other):

Preparation

Registered head office address

Ownership type (e.g. joint venture, partnership,

corporation, foreign investment, other)
Audit Execution

Year company formed

GSCP Reference Environmental Summary of Findings and Corrective Actions

Does the company own any other employment

sites?
If yes, how many and in which countries?

Annual turnover of company (USD$)

Audit Outputs

GSCP Reference Environmental Audit Checks

Glossary
Appendices

GSCP Reference Environmental Alert Notification

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GSCP Reference Environmental Self Assessment Questionnaire
Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire
Environmental Audit Process & Methodology Reference Tools - november 2010

Risk Assessment System

GSCP Reference Environmental Supplementary Audit Information
Employment Site Overview

Audit Request
Employment site name

Full address

GSCP Reference Environmental Pre-Audit Employment Site Profile

Preparation
Country

Employment site website

Employment site manager

Audit Execution
Name of person completing

GSCP Reference Environmental Summary of Findings and Corrective Actions

this questionnaire

Job Title/Role of person completing

this questionnaire

Telephone number of person completing

this questionnaire

Audit Outputs
Email address of person completing

GSCP Reference Environmental Audit Checks

this questionnaire

Glossary
Appendices
GSCP Reference Environmental Alert Notification

Global Social Compliance Programme_03

 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report

Industry sector:

Principal products:

Main raw materials used:

Main production processes

baking, harvesting, dyeing etc.):

(e.g. Stitching, labelling, injection, moulding,

04_Global Social Compliance Programme

Employment Site Production Systems and Processes
Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire
Environmental Audit Process & Methodology Reference Tools - november 2010
 GSCP Reference Environmental Audit Report

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GSCP Reference Environmental Self Assessment Questionnaire
Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire
Environmental Audit Process & Methodology Reference Tools - november 2010

Risk Assessment System

Employment Site Size and Location

What is the employment site size?

GSCP Reference Environmental Supplementary Audit Information

acres/hectares/m2 (please state units used)

Approximately, what area of the site is covered

by buildings (%):

Audit Request
What age are the buildings on-site (if known)?

Is the site owned or leased? Owned Leased

GSCP Reference Environmental Pre-Audit Employment Site Profile

Are there any other parties on site as tenants Yes No
or sub-tenants?

Preparation
If yes, please name them

Describe surrounding land use (residential,

industrial, rural etc.) and identify neighbouring
facilities and types:

Audit Execution
GSCP Reference Environmental Summary of Findings and Corrective Actions
North:

South:

East:

Audit Outputs
West:

GSCP Reference Environmental Audit Checks

State the distance to, and size of, the nearest
residential communities

Are there any sensitive habitats nearby,

such as nature reserves, national parks,

Glossary
wetlands or sites of special scientific interest?
If yes, please describe

What is the location of the nearest surface

Appendices

water course (river, stream, canal, lake, reservoir,

pond, etc.)?
GSCP Reference Environmental Alert Notification

Are there any boreholes/wells or natural springs

either on-site or in the surrounding area?

When was the site first developed from greenfield

(if known)?

Please summarise the previous land-uses

of the site (if known), e.g. type of operation,
occupier of the site etc.?

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GSCP Reference Environmental Self Assessment Questionnaire

Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire

Environmental Audit Process & Methodology Reference Tools - november 2010
Risk Assessment System

1. Environmental Management Systems

1.1 Does your site have a policy defining its approach to environmental Yes No
management?
GSCP Reference Environmental Supplementary Audit Information

If yes, please attach

1.2 Is your site committed to any industry or governmental environmental Yes No

codes?
Audit Request

If yes, please provide details

GSCP Reference Environmental Pre-Audit Employment Site Profile

1.3 Does your site have a dedicated manager who is responsible for Yes No
environmental issues?
Preparation

If yes, please specify exact title and name Name:

Title:

1.4 Has your site assessed its environmental risks? Yes No

1.5 Does your site have a system or process for assessing environmental risks Yes No
Audit Execution

associated with the introduction of new (or changes to existing) materials,

GSCP Reference Environmental Summary of Findings and Corrective Actions

processes or activities?

1.6 Does your site set environmental objectives and targets to improve Yes No
environmental performance (e.g. reductions in water use, reductions
in energy use, reductions in wastes generated)?
If yes, please provide details
Audit Outputs

GSCP Reference Environmental Audit Checks

1.7 Does your site have a system in place that will alert relevant personnel Yes No
to changes in any applicable environmental laws?
Glossary

1.8 Does your site have defined standards for suppliers (e.g. suppliers Yes No
of services, contractors, raw material suppliers) that prescribed expected
levels of environmental performance?
If yes, please attach a copy
Appendices

1.9 Does your site have a procedure in place to evaluate and select suppliers Yes No
(e.g. suppliers of services, contractors, raw material suppliers) based on
their ability to meet the standards mentioned in Q1.8?
If yes, please attach a copy
GSCP Reference Environmental Alert Notification

1.10 Is there a site environmental committee? Yes No

If yes, does this include representatives from various business functions? Yes No

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GSCP Reference Environmental Self Assessment Questionnaire
Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire
Environmental Audit Process & Methodology Reference Tools - november 2010

Risk Assessment System

1. Environmental Management Systems

1.11 Does your site have procedures in place to control the way work is done Yes No
or activities are completed that address environmental issues?

GSCP Reference Environmental Supplementary Audit Information

1.12 Does your site have specific written environmental procedures Yes No
(e.g. for waste handling and disposal, spill prevention etc.)?

Audit Request
1.13 Are all workers (including temporary workers) trained on relevant Yes No
environmental matters and how they, as individuals, may impact
the environment?

GSCP Reference Environmental Pre-Audit Employment Site Profile

1.14 Is this training repeated on a regular basis? Yes No
If yes, how often does this occur?

Preparation
1.15 Does your site have records of the names of all personnel trained Yes No
and the dates they were trained?

Audit Execution
1.16 Are visitors provided with any instructions or information in relation Yes No N/A

GSCP Reference Environmental Summary of Findings and Corrective Actions

to environmental matters and site rules?

1.17 Are contractors/third party workers provided with training in relation Yes No N/A
to environmental matters and site environmental procedures?

1.18 Does your site have a process for periodically reviewing its environmental Yes No
performance?

Audit Outputs
If yes, please describe

GSCP Reference Environmental Audit Checks

Glossary
Appendices
GSCP Reference Environmental Alert Notification

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GSCP Reference Environmental Self Assessment Questionnaire

Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire

Environmental Audit Process & Methodology Reference Tools - november 2010
Risk Assessment System

2. Energy Use, Transport and Greenhouse Gases (GHGs)

2.1 What energy sources does your site use (e.g. mains electricity, locally Sources:
generated electricity, coal, oil, gas etc.)?
GSCP Reference Environmental Supplementary Audit Information

Please explain what they are and what they are used for

2.2 Does your site purchase any energy from renewable sources Yes No
Audit Request

(e.g. solar, wind etc.)?

If so, please provide further details
GSCP Reference Environmental Pre-Audit Employment Site Profile

2.3 Does your site have systems or procedures in place that seek to reduce
the site’s environmental impact from:
Preparation

• Energy? Yes No N/A

• Transport? Yes No N/A
• Greenhouse gases (GHGs) Yes No N/A

2.4 Does your site provide training to relevant personnel in relation to:
• Energy? Yes No N/A
• Transport? Yes No N/A
Audit Execution

• Greenhouse gases (GHGs)? Yes No N/A

GSCP Reference Environmental Summary of Findings and Corrective Actions

2.5 Does your site monitor and track energy consumption? Yes No N/A
If yes, please specify how it tracks energy use and provide approximate
consumption figures for the energy sources listed in 2.1 on an annual
basis/12 month period
Audit Outputs

2.6 Is your site part of a recognised compliance scheme for greenhouse gas Yes No N/A
GSCP Reference Environmental Audit Checks

(GHG) emissions trading?

If yes, please provide details of the scheme (e.g. who runs it
and the employment site’s membership reference)
Glossary

2.7 Has your site set any targets in relation to increase efficiency of:
• Energy use? Yes No N/A
• Transport use? Yes No N/A
• Greenhouse gas (GHG) generation? Yes No N/A
Appendices

2.8 Does your site conduct site energy audits? Yes No

If yes, how often are these undertaken and when was the most recent audit? How often:
GSCP Reference Environmental Alert Notification

Date of most recent audit:

2.9 Is your site required to monitor or calculate energy and/or GHG emissions Yes No N/A
to demonstrate compliance with applicable permits?

2.10 Does your site monitor or routinely assess emissions of GHGs associated Yes No N/A
with site processes/activities, fuel use for on-site or off-site transportation,
agricultural activities etc.?

2.11 Does your site monitor or routinely assess emissions of fluorinated-gases Yes No N/A
(F-gases)?

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GSCP Reference Environmental Self Assessment Questionnaire
Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire
Environmental Audit Process & Methodology Reference Tools - november 2010

Risk Assessment System

3. Water Use

3.1 What sources of water are used at your site (e.g. mains drinking water, Sources:
mains process water, borehole abstraction, surface water abstraction etc.)?

GSCP Reference Environmental Supplementary Audit Information

Please explain what they are and what they are used for

Audit Request
3.2 If your site uses water abstracted from on-site boreholes or from rivers, Yes No N/A
streams, lakes etc. does it require a permit or licence for this activity?
If yes, are there limits and/or conditions associated with this permit/licence? Yes No N/A

GSCP Reference Environmental Pre-Audit Employment Site Profile

3.3 Does your site have systems or procedures in place that manage water Yes No N/A
consumption/use?

Preparation
3.4 Does your site provide training to relevant personnel in relation to water use? Yes No N/A

3.5 Has your site set any targets in relation to reducing water consumption? Yes No N/A

3.6 Does your site monitor and track water consumption? Yes No
If yes, please specify how it tracks water use and provide approximate

Audit Execution
consumption figures for all water sources on an annual basis/12 month period

GSCP Reference Environmental Summary of Findings and Corrective Actions

Is monitoring and tracking of water consumption a legal requirement Yes No
for your site?

3.7 Does your site conduct water audits (or other similar exercises) to identify Yes No

Audit Outputs
where water is being used, whether there are any leaks, whether water is
being wasted etc.?

GSCP Reference Environmental Audit Checks

If yes, how often are these undertaken and when was the most recent audit? How often:

Date of most recent audit:

Glossary
3.8 Does your site use ‘grey’ water? (e.g. water typically generated from Yes No
domestic-style activities, for example washing machines, showers,
bathtubs, hand washing, and sinks, together with some industrial processes)
and recycled on-site)
Appendices

3.9 Is your site free from any fines, prosecution or warning by the regulators Yes No
in relation to water use?
GSCP Reference Environmental Alert Notification

If not, please provide details (including reason for fine/prosecution/warning,

the date on which it occurred, the cost of any fine/details of any custodial
sentence or restriction on site activities and whether the matter has been
resolved or is ongoing)

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GSCP Reference Environmental Self Assessment Questionnaire

Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire

Environmental Audit Process & Methodology Reference Tools - november 2010
Risk Assessment System

4. Wastewater / Effluent

4.1 What wastewater/effluent streams are generated at your site? Streams:

Please describe
GSCP Reference Environmental Supplementary Audit Information

4.2 Is there a dedicated drainage system on-site? Yes No N/A

Audit Request

If yes, please describe the drainage systems present

4.3 Where does wastewater/effluent from your site discharge to (municipal

GSCP Reference Environmental Pre-Audit Employment Site Profile

sewer, river, lake, sea etc.)?

Please describe
Preparation

4.4 Does your site treat wastewater/effluent prior to off-site discharge? Yes No N/A

Is there a dedicated onsite wastewater/effluent treatment plant? Yes No N/A

Audit Execution

4.5 Does your site hold the necessary licence or permit for discharging Yes No N/A
GSCP Reference Environmental Summary of Findings and Corrective Actions

wastewater/effluent via the drainage system?

If so, please provide brief details

4.6 If your site does have a permit/licence, has your site been fully in Yes No N/A
Audit Outputs

compliance with the requirements and conditions of the permit/licence

for the last three years?
GSCP Reference Environmental Audit Checks

4.7 Is your site required to sample/test wastewater discharges? Yes No N/A

If yes, please provide details including frequency of testing and whether
this is undertaken on-site or outsourced to an external contractor
Glossary

4.8 Does your site have systems or procedures in place that address wastewater Yes No N/A
generation and management?

4.9 Does your site provide training to relevant personnel in relation Yes No N/A
Appendices

to wastewater management?

4.10 Has your site set any targets in relation to reducing the volume Yes No N/A
GSCP Reference Environmental Alert Notification

of wastewater generated?

4.11 Is your site free from fines, prosecution or warneing by the regulators in Yes No
relation to wastewater management?
If not, please provide details (including reason for fine/prosecution/warning,
the date on which it occurred, the cost of any fine/details of any custodial
sentence or restriction on site activities and whether the matter has been
resolved or is ongoing)

10_Global Social Compliance Programme

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GSCP Reference Environmental Self Assessment Questionnaire
Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire
Environmental Audit Process & Methodology Reference Tools - november 2010

Risk Assessment System

5. Emissions to Air

5.1 What are the main point source emissions to air at your site Sources:
(point source emissions are those which discharge via a chimney, stack,

GSCP Reference Environmental Supplementary Audit Information

extraction system or vent)?
Please describe

Audit Request
5.2 What are the main fugitive emissions to air at your site (fugitive emissions Sources:
are those which are not controlled (e.g. emissions from a plating bath into
the general factory atmosphere and/or unplanned emissions, e.g. leaks from
equipment, pipes etc.)?

GSCP Reference Environmental Pre-Audit Employment Site Profile

Please describe

Preparation
5.3 Are there abatement or pollution prevention devices (e.g. filters, scrubbers) Yes No N/A
on point source emissions to air?
If so, please describe the abatement techniques employed at the site

Audit Execution
GSCP Reference Environmental Summary of Findings and Corrective Actions
5.4 Does your site hold the necessary licences or permits for emissions to air? Yes No N/A
If so, please provide brief details

5.5 If your site does have a permit/licence, has your site been fully Yes No N/A

Audit Outputs
in compliance with the requirements and conditions of the permit/licence
for the last three years?

GSCP Reference Environmental Audit Checks

5.6 Does your site sample/test emissions to air? Yes No N/A
If yes, please provide details including frequency of testing and whether
this is undertaken by site personnel or outsourced to an external contractor

5.7 Does your site have an inventory of equipment on-site that contains ozone Yes No N/A Glossary
depleting substances (ODSs) (e.g. air conditioning equipment that contains
refrigerants)?
Appendices

If so, please describe the types and quantities of refrigerants/ODSs present on-site
GSCP Reference Environmental Alert Notification

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GSCP Reference Environmental Self Assessment Questionnaire

Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire

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…
Risk Assessment System

5. Emissions to Air

5.8 Is your site phasing-out the use of ODSs? Yes No N/A

Is the phase-out a legal requirement for your site? Yes No N/A
GSCP Reference Environmental Supplementary Audit Information

If yes, please provide details of phasing out

Audit Request

5.9 Is there a routine or periodic maintenance/inspection programme Yes No N/A

in place to test for leaks of ODSs?

If yes, is this conducted by a specialist external contractor? Yes No N/A

GSCP Reference Environmental Pre-Audit Employment Site Profile

5.10 Does your site have systems or procedures in place that manage:
• Emissions to air? Yes No N/A
Preparation

• ODSs? Yes No N/A

5.11 Does your site provide training to relevant personnel in relation to:
• Emissions to air? Yes No N/A
• ODSs? Yes No N/A
Audit Execution

5.12 Has your site set any targets in relation to reducing:

GSCP Reference Environmental Summary of Findings and Corrective Actions

• Emissions to air? Yes No N/A

• Quantity of ODSs used on-site? Yes No N/A

5.13 Is your site free from any fines, prosecution or warning by the regulators Yes No
in relation to emissions to air or ODSs?
If not, please provide details (including reason for fine/prosecution/warning,
Audit Outputs

the date on which it occurred, the cost of any fine/details of any custodial
sentence or restriction on site activities and whether the matter has been
GSCP Reference Environmental Audit Checks

resolved or is ongoing)
Glossary
Appendices

GSCP Reference Environmental Alert Notification

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introduction
GSCP Reference Environmental Self Assessment Questionnaire
Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire
Environmental Audit Process & Methodology Reference Tools - november 2010

Risk Assessment System

6. Waste Management

6.1 Does your site generate hazardous waste? Yes No

Typically, hazardous waste is waste that could cause harm to public health and/

GSCP Reference Environmental Supplementary Audit Information

or the environment because of its chemical, physical or biological characteristics
(e.g., it is flammable, explosive, toxic, radioactive, or infectious).
If yes, please list

Audit Request
6.2 What are the main non-hazardous waste your site generates?
Please list

GSCP Reference Environmental Pre-Audit Employment Site Profile

Preparation
6.3 Does your site have systems or procedures in place that address waste Yes No N/A
management?

6.4 Are site waste audits undertaken (to identify what wastes are generated Yes No
where and to identify what opportunities there may be for reducing waste
or improving the management of waste)?

Audit Execution
GSCP Reference Environmental Summary of Findings and Corrective Actions
If yes, how often are these undertaken and when was the most recent audit? How often:

Date of most recent audit:

6.5 Are waste materials recycled (either on-site or off-site)? Yes No

Audit Outputs
If yes, please provide details

GSCP Reference Environmental Audit Checks

6.6 Is your site required to be registered as a waste producer with the regulatory Yes No
authorities?
If yes, please provide details

Glossary
6.7 Are hazardous wastes separated from non-hazardous waste streams? Yes No N/A
If yes, please describe
Appendices
GSCP Reference Environmental Alert Notification

6.8 Does your site treat wastes on-site prior to off-site disposal? Yes No

If yes, are you required to have a licence or permit do undertake this activity? Yes No N/A

6.9 Does your site burn wastes on-site? Yes No

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GSCP Reference Environmental Self Assessment Questionnaire

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Risk Assessment System

6. Waste Management

6.10 Does your site bury or dispose of wastes on-site? Yes No

GSCP Reference Environmental Supplementary Audit Information

6.11 Does your site use external waste contractors? Yes No

If yes, is there a choice of which waste contractor company your site can use? Yes No N/A
Audit Request

6.12 If external waste contractors are used, does your site undertake regular Yes No N/A
checks/audits of those contractors?

6.13 Are waste contractors required to be licensed by a regulator or local Yes No N/A
GSCP Reference Environmental Pre-Audit Employment Site Profile

authority?

6.14 Does your site retain copies of waste contractor licences and permits Yes No N/A
Preparation

on-site?

6.15 Does your site retain records of off-site transfer, treatment and disposal Yes No N/A
of your wastes?
If yes, how often are these retained for? Retention period:
Audit Execution

GSCP Reference Environmental Summary of Findings and Corrective Actions

If no, does your site know the final destination of its wastes? Yes No N/A

6.16 Does your site provide training to relevant personnel in relation to waste Yes No N/A
management?

6.17 Has your site set any targets in relation to reducing the volume of waste Yes No N/A
Audit Outputs

generated?
GSCP Reference Environmental Audit Checks

6.18 Is your site free from any fines, prosecution or warning by the regulators Yes No
in relation to waste issues?
If not, please provide details (including reason for fine/prosecution/warning,
the date on which it occurred, the cost of any fine/details of any custodial
sentence or restriction on site activities and whether the matter has been
Glossary

resolved or is ongoing)
Appendices

GSCP Reference Environmental Alert Notification

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GSCP Reference Environmental Self Assessment Questionnaire
Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire
Environmental Audit Process & Methodology Reference Tools - november 2010

Risk Assessment System

7. Pollution Prevention / Hazardous and Potentially Hazardous Substances

7.1 Does your site store, use or handle hazardous or potentially hazardous Yes No
substances?

GSCP Reference Environmental Supplementary Audit Information

If yes, what are the main ones?

Audit Request
If yes, does it maintain an inventory of those hazardous substances? Yes No N/A

7.2 Does your site have systems or procedures in place that address pollution Yes No N/A
prevention and the management of hazardous and potentially hazardous
substances?

GSCP Reference Environmental Pre-Audit Employment Site Profile

If yes, please describe

Preparation
7.3 Is your site required to hold a licence or permit for the hazardous substances Yes No N/A
present on-site?

If yes, does it hold the requisite licence or permit? Yes No N/A

Audit Execution
GSCP Reference Environmental Summary of Findings and Corrective Actions
7.4 Has your site assessed whether any substances stored, used or handled on-site Yes No N/A
are prohibited by national or international laws or protocols?

7.5 Does your site maintain up to date safety data sheets (or similar) Yes No N/A
for all hazardous substances used on-site?

Audit Outputs
7.6 Does your site provide training to relevant personnel in relation Yes No N/A
to the management and use of hazardous substances?

GSCP Reference Environmental Audit Checks

7.7 Has your site set any targets in relation to eliminating or reducing hazardous Yes No N/A
substances used on-site?

7.8 Has your site assessed whether polychlorinated biphenyls (PCBs) are present Yes No N/A

Glossary
in equipment on-site?

…
Appendices
GSCP Reference Environmental Alert Notification

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GSCP Reference Environmental Self Assessment Questionnaire

Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire

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…
Risk Assessment System

7. Pollution Prevention / Hazardous and Potentially Hazardous Substances

7.9 Has your site assessed whether asbestos-containing materials are present Yes No N/A
on-site?
GSCP Reference Environmental Supplementary Audit Information

7.10 If asbestos containing materials are present, has the site compiled an Yes No N/A
asbestos register (or similar)?
If yes, please provide details
Audit Request

7.11 Are there any above ground or underground bulk storage tanks present Yes No
GSCP Reference Environmental Pre-Audit Employment Site Profile

on-site?
If yes, please describe number, size and substance stored
Preparation

7.12 If above ground tanks are present on-site, are they provided with secondary Yes No N/A
containment or equivalent?

7.13 Does your site conduct integrity testing of bulk storage tanks? Yes No N/A
Audit Execution

If yes, please describe the frequency of testing and when the last testing
GSCP Reference Environmental Summary of Findings and Corrective Actions

was carried out

7.14 Does your site have emergency spill response (e.g. spill kits, spill response Yes No N/A
team etc.)?
If yes, please describe
Audit Outputs

GSCP Reference Environmental Audit Checks

7.15 Have there been any instances of incidents/spills of hazardous or potentially Yes No
hazardous materials on-site (or of off-site incidents caused by your site’s
activities) in the past two years?
Glossary

If yes, please provide details

7.16 Is your site free from any fines, prosecution or warning by the regulators Yes No
Appendices

in relation to the storage or use of hazardous substances?

If not, please provide details (including reason for fine/prosecution/warning,
the date on which it occurred, the cost of any fine/details of any custodial
sentence or restriction on site activities and whether the matter has been
GSCP Reference Environmental Alert Notification

resolved or is ongoing)

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GSCP Reference Environmental Self Assessment Questionnaire
Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire
Environmental Audit Process & Methodology Reference Tools - november 2010

Risk Assessment System

8. Major Incident Management

8.1 Have there been any major incidents at your site in the past 2 years? Yes No
If yes, please provide details

GSCP Reference Environmental Supplementary Audit Information

8.2 Is your site required to hold a permit/licence or be notified to the authorities Yes No

Audit Request
given the potential for a major incident?

8.3 Does your site have a site emergency response plan and/or procedure? Yes No N/A

GSCP Reference Environmental Pre-Audit Employment Site Profile

8.4 Are people trained in what to do in an emergency? Yes No

8.5 Are local communities or emergency services involved in the development Yes No N/A

Preparation
or review of the plan?

8.6 Has your site communicated the emergency response plan to those parties Yes No N/A
that could be impacted?
If yes, please provide brief details

Audit Execution
GSCP Reference Environmental Summary of Findings and Corrective Actions
8.7 Are drills or major incident scenarios practised? Yes No N/A

8.8 Is your site free from any fines, prosecution or warning by the regulators Yes No
in relation to any major incidents on-site or caused by the site?
If not, please provide details (including reason for fine/prosecution/warning,

Audit Outputs
the date on which it occurred, the cost of any fine/details of any custodial
sentence or restriction on site activities and whether the matter has been
resolved or is ongoing)

GSCP Reference Environmental Audit Checks

Glossary
Appendices
GSCP Reference Environmental Alert Notification

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GSCP Reference Environmental Self Assessment Questionnaire

Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire

Environmental Audit Process & Methodology Reference Tools - november 2010
Risk Assessment System

9. Contaminated Land/Soil and Groundwater Pollution Prevention

9.1 Has your site assessed the site sensitivity and potential pathways and Yes No
receptors in the vicinity of the employment site?
GSCP Reference Environmental Supplementary Audit Information

If yes, please briefly describe the sensitivity of the site

Audit Request

9.2 Has your site identified any known impact to soil and groundwater Yes No
from current activities/operations (is there soil and/or groundwater
contamination)?
GSCP Reference Environmental Pre-Audit Employment Site Profile

9.3 Has your site undertaken any previous intrusive soil and groundwater Yes No Not required
investigations?
If yes, please provide brief details of the extent and nature of the investigations
Preparation

9.4 If yes to 9.3 has any soil and groundwater contamination been identified? Yes No N/A

9.5 Is your site aware of any legal requirements in relation to contaminated Yes No
Audit Execution

land?
GSCP Reference Environmental Summary of Findings and Corrective Actions

If yes, does this include an awareness of the requirements in relation to the Yes No N/A
assessment, investigation, remediation and soil and groundwater pollution
prevention?

9.6 Does your site provide training to relevant personnel in relation Yes No N/A
to the prevention of soil and groundwater pollution?
Audit Outputs

9.7 Is your site free from any fines, prosecution or warning by the regulators Yes No
GSCP Reference Environmental Audit Checks

in relation to soil or groundwater contamination?

If not, please provide details (including reason for fine/prosecution/warning,
the date on which it occurred, the cost of any fine/details of any custodial
sentence or restriction on site activities and whether the matter has been
resolved or is ongoing)
Glossary
Appendices

GSCP Reference Environmental Alert Notification

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GSCP Reference Environmental Self Assessment Questionnaire
Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire
Environmental Audit Process & Methodology Reference Tools - november 2010

Risk Assessment System

10. Land Use and Biodiversity

10.1 Has your site assessed the potential impacts of the site operations Yes No
on designated protected areas or the ecosystem (plants, animals

GSCP Reference Environmental Supplementary Audit Information

and microorganisms)?

10.2 Is your site aware of the legal requirements in relation to land use Yes No
and biodiversity that apply to the employment site?

Audit Request
10.3 Is the site required to hold a permit/licence in relation to land use Yes No
or biodiversity issues?

GSCP Reference Environmental Pre-Audit Employment Site Profile

10.4 Are there any identified protected habitats or species on the employment site Yes No
or in the immediate surrounding areas?
If yes, please briefly describe

Preparation
10.5 Has your site implemented any control measures to minimise impacts Yes No
to biodiversity?
If yes, please provide brief details

Audit Execution
GSCP Reference Environmental Summary of Findings and Corrective Actions
10.6 Does your site provide training to relevant personnel on land use Yes No
and biodiversity issues?

10.7 Does your site assess land use implications and legal requirements when Yes No
planning major on-site projects or expansions?

Audit Outputs
10.8 Is your site free from any fines, prosecution or warning by the regulators Yes No

GSCP Reference Environmental Audit Checks

in relation to land use or impacts on biodiversity?
If not, please provide details (including reason for fine/prosecution/warning,
the date on which it occurred, the cost of any fine/details of any custodial
sentence or restriction on site activities and whether the matter has been
resolved or is ongoing)

Glossary
Appendices
GSCP Reference Environmental Alert Notification

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GSCP Reference Environmental Self Assessment Questionnaire

Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire

Environmental Audit Process & Methodology Reference Tools - november 2010
Risk Assessment System

11. Nuisance

11.1 Has your site identified where there is the potential for nuisance could be Yes No
caused by on-site operations?
GSCP Reference Environmental Supplementary Audit Information

11.2 If yes to 11.1, what sources (e.g. noise, dust, odour, visual, litter) of potential Types of nuisance:
nuisance has your site identified and assessed?
Audit Request

11.3 Has your site assessed potential nuisance that might arise from non-routine Yes No
or out of hours’ operations/activities?
GSCP Reference Environmental Pre-Audit Employment Site Profile

11.4 Does your site have systems or procedures in place that manage/reduce Yes No
the potential for the site to cause nuisance?
Preparation

11.5 Has your site received any instances of nuisance or complaints relating to Yes No
on-site activities in the last 2 years?
If yes, please provide details as to the nature and extent of these

If yes, does your site maintain a log of nuisance/complaints? Yes No

Audit Execution

GSCP Reference Environmental Summary of Findings and Corrective Actions

11.6 Does your site provide training to relevant personnel in how to reduce Yes No
the potential for nuisance and complaints?

11.7 Is your site free from any fines, prosecution or warning by the regulators in Yes No
relation to nuisance or complaints?
If not, please provide details (including reason for fine/prosecution/warning,
Audit Outputs

the date on which it occurred, the cost of any fine/details of any custodial
sentence or restriction on site activities and whether the matter has been
resolved or is ongoing)
GSCP Reference Environmental Audit Checks
Glossary

END OF QUESTIONNAIRE
Appendices

GSCP Reference Environmental Alert Notification

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GSCP Reference Environmental Self Assessment Questionnaire

introduction
Appendix 2
GSCP Reference

Risk Assessment System

Environmental
Pre-Audit Employment

GSCP Reference Environmental Supplementary Audit Information

Site Profile

Audit Request
GSCP Reference Environmental Pre-Audit Employment Site Profile
This tool forms part of the GSCP set of reference tools Recommended timeframe:
designed to provide a common interpretation of local and

Preparation
• the auditor should supply the pre-audit employment site
international environmental standards and requirements and
profile questionnaire to the employment site within five
environmental reference codes (if available and applicable).
working days of the audit being confirmed;
The Environmental Reference Requirements reflect a
common understanding of good environmental practice and • the pre-audit employment site profile questionnaire should
are applicable to all raw material processing, agricultural, be completed and returned to the auditor two weeks from
manufacturing and logistics sites in the supply chain. The the date of the request being made;

Audit Execution
Environmental Reference Requirements provide a model
• if an audit is requested and scheduled in less than two

GSCP Reference Environmental Summary of Findings and Corrective Actions

for a site in the supply chain to demonstrate continuous
weeks, the auditor and employment site should work
improvement in its environmental performance from basic
together to ensure the pre-audit employment site profile
compliance to leading-edge performance (across three
is returned as soon as possible and in any event before the
defined ‘levels’ for eleven different performance areas).
audit is carried out.
The reference tools on Environmental Audit Process and
Methodology are based on the GSCP Environmental

Audit Outputs
Reference Requirements but can be adopted and tailored to Note on updates
other codes of environmental practice.

GSCP Reference Environmental Audit Checks

When an audit request is made, the auditor should send the It will be agreed between the buying company, the auditor
employment site a PRE-AUDIT EMPLOYMENT SITE PROFILE and the site as to whether a full pre-audit profile would be
questionnaire asking for general information about location, required each time, or whether just an update of information
size, production processes and activities and various that had changed would be needed.
environmental matters. This information allows auditors to: A pre-audit employment site profile should have four main

Glossary
• prepare relevant briefing materials (industry or country- areas:
specific); 1. company Overview;
• plan the assessment, for example the required number of 2. employment Site Details;
audit days;
Appendices

3. environmental Matters;
• focus the audit on priority or higher risk areas and topics.
4. subcontractor Details.
The audit company should communicate the following to
GSCP Reference Environmental Alert Notification

each employment site to be audited and any relevant parties, Where the employment site itself is the audit requestor, the
such as agents, in the supply chain: auditor should ensure that an agreement is in place with the
employment site to allow the auditor to communicate audit
• the importance of accuracy in completing in the pre-audit findings and any alert notifications to any buyers, brands or
employment site profile; retailers concerned.
• timeframe for completion of the pre-audit employment
site profile;
• to whom to send the completed pre-audit employment
site profile.

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GSCP Reference Environmental Self Assessment Questionnaire
introduction

Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

Environmental Audit Process & Methodology Reference Tools - november 2010
Risk Assessment System

1. Company Overview
GSCP Reference Environmental Supplementary Audit Information

Where possible, the pre-audit employment site profile should detail the following overview of the company.

Company Overview
Audit Request

Name of company which owns the employment

GSCP Reference Environmental Pre-Audit Employment Site Profile

site to be audited:

Registered head office address:

Mailing address of company

(if different to that of the employment site):
Preparation

Telephone number:

Fax number:

Ownership type (e.g. joint venture, partnership,

Audit Execution

corporation, foreign investment, other):

GSCP Reference Environmental Summary of Findings and Corrective Actions

Year company formed:

Business licence No. (if applicable)

Does the company own any other employment

Audit Outputs

sites?
If yes, how many?
GSCP Reference Environmental Audit Checks
Glossary
Appendices

GSCP Reference Environmental Alert Notification

02_Global Social Compliance Programme

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GSCP Reference Environmental Self Assessment Questionnaire

introduction
Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile
Environmental Audit Process & Methodology Reference Tools - november 2010

Risk Assessment System

2. Employment Site Details
2.1 Employment Site Contact Details

GSCP Reference Environmental Supplementary Audit Information

The pre-audit employment site profile questionnaire should request the following contact information.

Audit Request
2.1 Employment Site Contact Details

GSCP Reference Environmental Pre-Audit Employment Site Profile

Employment site name:

Full address:

Full address

Preparation
(in local language, if applicable):

Country

Is this site in an Export Processing Yes No

Zone (EPZ)?

Audit Execution
Employment site telephone number:

GSCP Reference Environmental Summary of Findings and Corrective Actions

Employment site fax number:

Employment site email address:

Reception opening hours’, if applicable

Employment site manager:

Audit Outputs
Languages of the employment site
management:

GSCP Reference Environmental Audit Checks

Please list the main languages spoken
by employment site managers:

Key audit contact:

Glossary
Key contact job title:

Key contact telephone number:

Key contact email address

Appendices

Name of person completing this

questionnaire (if different to key audit
contact):
GSCP Reference Environmental Alert Notification

Telephone number of person

completing this questionnaire:

Email address of person completing

this questionnaire:

Employment site website (if available):

Closest airport/railway station:

Distance from the above:

please specify time and distance plus
traffic conditions if relevant

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GSCP Reference Environmental Self Assessment Questionnaire
introduction

Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

Environmental Audit Process & Methodology Reference Tools - november 2010
Risk Assessment System

2.2 Employment Site Environmental Management

The following information is requested to understand internal environmental management systems...
GSCP Reference Environmental Supplementary Audit Information

2.2 Employment Site Environmental Management

Name and job title of person Name:

responsible for environmental issues:
Job Title:
Audit Request

GSCP Reference Environmental Pre-Audit Employment Site Profile

Does the site have an environmental Yes No

policy?

Has the site developed an Yes No

environmental management system?
Preparation

If yes, is the site’s environmental Yes No

management system certified
to a recognised standard, e.g. 14001,
EMAS, etc.
If yes, please state which standard
Audit Execution

Is there an environmental committee Yes No

on-site?
GSCP Reference Environmental Summary of Findings and Corrective Actions

Are internal environmental audits ever Yes No

carried out?
If so, please state by whom
and the date of the most recent audit

Are environmental audits ever carried Yes No

Audit Outputs

out by external companies/third

parties?
GSCP Reference Environmental Audit Checks

If so, please state by whom

and the date of the most recent audit
Glossary
Appendices

GSCP Reference Environmental Alert Notification

04_Global Social Compliance Programme

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GSCP Reference Environmental Self Assessment Questionnaire

introduction
Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile
Environmental Audit Process & Methodology Reference Tools - november 2010

Risk Assessment System

2.3 Employment Site Area, Location and Surrounding Land Uses
The pre-audit employment site profile questionnaire should detail the following information concerning the size of the
employment site, its location and surrounding land uses.

GSCP Reference Environmental Supplementary Audit Information

Where relevant, the employment site should be asked to submit a site plan.

2.3 Employment Site Size, Location & Surrounding Land uses

Audit Request
What is the employment site size?

GSCP Reference Environmental Pre-Audit Employment Site Profile

acres/hectares/m2 (please state units used)

Approximately, what area of the site is covered

by buildings (%):

Preparation
What age are the buildings on-site (if known)?

Is the site owned or leased? Owned Leased

If leased, who is the landlord? Landlord:

Audit Execution
Are there any other parties on site as tenants Yes No
or sub-tenants?

GSCP Reference Environmental Summary of Findings and Corrective Actions

If yes, please name them

Describe surrounding land use (residential,

industrial, rural etc.) and identify neighbouring

Audit Outputs
facilities and types:

GSCP Reference Environmental Audit Checks

North:

South:

East:

Glossary
West:

…
Appendices
GSCP Reference Environmental Alert Notification

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GSCP Reference Environmental Self Assessment Questionnaire
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Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

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…
Risk Assessment System

2.3 Employment Site Size, Location & Surrounding Landuses

State the distance to, and size of the nearest

residential community and sensitive sites
GSCP Reference Environmental Supplementary Audit Information

(e.g. schools, hospitals, etc.)

Are there any sensitive habitats nearby, Yes No

such as nature reserves, national parks,
wetlands or sites of special scientific interest?
Audit Request

GSCP Reference Environmental Pre-Audit Employment Site Profile

If yes, please describe

Briefly describe the geology beneath the site

(if known)
Preparation

What is the location of the nearest surface water Name of water course:
courses? Distance and direction from site:
Use:
Official grade of water quality if applicable/known
Audit Execution

GSCP Reference Environmental Summary of Findings and Corrective Actions

Name of water course:

Distance and direction from site:
Use:
Official grade of water quality if applicable/known
Audit Outputs

Are there any boreholes/wells or natural springs Yes No

either on-site or in the surrounding area?
GSCP Reference Environmental Audit Checks

If yes, please provide the following information: Well, Borehole or Spring:

Location:
Use:
Glossary

Well, Borehole or Spring:

Location:
Use:
Appendices

GSCP Reference Environmental Alert Notification

06_Global Social Compliance Programme

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GSCP Reference Environmental Self Assessment Questionnaire

introduction
Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile
Environmental Audit Process & Methodology Reference Tools - november 2010

Risk Assessment System

2.4 Employment Site Production and Processes Overview
The pre-audit employment site profile should detail the following information concerning the employment site’s production
systems and production processes. Some employment sites may not be willing to provide some of the information requested

GSCP Reference Environmental Supplementary Audit Information

because of confidentiality agreements with other customers.

2.4 Employment Site Production Systems and Processes

Audit Request
Industry sector:

GSCP Reference Environmental Pre-Audit Employment Site Profile

Principal products:

Main export markets:

Preparation
Main production processes:

Main production equipment:

Main raw materials used:

Audit Execution
GSCP Reference Environmental Summary of Findings and Corrective Actions
Hazardous chemicals used on-site:

Does the site produce electrical or Yes No N/A

electronic products?
If yes, please state which products

Audit Outputs
GSCP Reference Environmental Audit Checks
Does your site use any of the following Yes No N/A
materials in its products (or their
components):
• Lead
• Mercury

Glossary
• Hexavalent chromium
• Cadmium
• Polybrominated biphenyls
• Polybrominated diphenyl ethers
Appendices

If yes, please state which

GSCP Reference Environmental Alert Notification

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GSCP Reference Environmental Self Assessment Questionnaire
introduction

Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

Environmental Audit Process & Methodology Reference Tools - november 2010

…
Risk Assessment System

2.4 Employment Site Production Systems and Processes

Are any of the following present on-site:

GSCP Reference Environmental Supplementary Audit Information

Boilers Yes No N/A

Air compressors Yes No N/A

Audit Request

Cooling towers or evaporative Yes No N/A

GSCP Reference Environmental Pre-Audit Employment Site Profile

condensers

Electrical substations/transformers/ Yes No N/A

switch-gear

Air conditioning equipment Yes No N/A

Preparation

Automated gas fire suppression Yes No N/A

systems (e.g. halon systems)

Operational Times Yes No N/A

Audit Execution

Number of operational weeks per Yes No N/A

GSCP Reference Environmental Summary of Findings and Corrective Actions

year:

Number of operational days per week: Yes No N/A

Typical hours of operation:

Audit Outputs

Scheduled site shut-downs:

GSCP Reference Environmental Audit Checks
Glossary
Appendices

GSCP Reference Environmental Alert Notification

08_Global Social Compliance Programme

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GSCP Reference Environmental Self Assessment Questionnaire

introduction
Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile
Environmental Audit Process & Methodology Reference Tools - november 2010

Risk Assessment System

2.5 Employment Site Workforce
The following information is an essential requirement, both to understand potential risks posed by the employment site’s
operations and to plan for the audit. Any missing details should be clarified with the employment site directly.

GSCP Reference Environmental Supplementary Audit Information

2.5 Employment Site Workforce

Total number of workers

Audit Request
at the employment site:

GSCP Reference Environmental Pre-Audit Employment Site Profile

Of which, how many are permanent
workers?

And how many are temporary

or agency workers?

Preparation
Language(s) spoken
Please detail the different native
languages of the workforce

Audit Execution
GSCP Reference Environmental Summary of Findings and Corrective Actions
Nationality of workers
Please detail the different nationalities
of the workforce

Does the site use contractors Yes No N/A

Audit Outputs
to perform any activities on-site?
If yes, please provide a brief overview

GSCP Reference Environmental Audit Checks

of contracted activities

Glossary
Appendices
GSCP Reference Environmental Alert Notification

Global Social Compliance Programme_09

 GSCP Reference Environmental Audit Report
GSCP Reference Environmental Self Assessment Questionnaire
introduction

Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

Environmental Audit Process & Methodology Reference Tools - november 2010
Risk Assessment System

3. Environmental Matters
GSCP Reference Environmental Supplementary Audit Information

Where possible, the pre-audit employment site profile should detail the following information relation to environmental
matters at the employment site.

3.1 Environmental Matters

Audit Request

Environmental permitting
GSCP Reference Environmental Pre-Audit Employment Site Profile

Is the facility subject to any integrated Yes No

environmental operating permits?
If yes, what are the particular
processes/activities or quantities of
chemicals stored at the site which
Preparation

attract this permitting requirement?

When was the permit granted and

on what date will it require renewal?

Are any changes planned in the next Yes No

Audit Execution

5 years which will require a new permit

GSCP Reference Environmental Summary of Findings and Corrective Actions

or existing permit modification?

If yes, please describe

Energy
Audit Outputs

Which of the following sources of energy are used on-site:

GSCP Reference Environmental Audit Checks

Mains gas Yes No

Liquefied petroleum gas Yes No

Mains electricity Yes No

Glossary

On-site generated electricity Yes No

Fuel oil (or gas oil) Yes No

Appendices

Coal Yes No
GSCP Reference Environmental Alert Notification

Timber Yes No

Other Yes No
(please specify)

10_Global Social Compliance Programme

 GSCP Reference Environmental Audit Report
GSCP Reference Environmental Self Assessment Questionnaire

introduction
Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile
Environmental Audit Process & Methodology Reference Tools - november 2010

Risk Assessment System

Water

Which of the following sources of water are used on-site:

GSCP Reference Environmental Supplementary Audit Information

Municipal mains water Yes No

Groundwater Yes No
(from wells/boreholes)

Audit Request
GSCP Reference Environmental Pre-Audit Employment Site Profile
Surface water Yes No
(e.g. from river, lake, pond etc.)

Other Yes No
(please specify)

Preparation
Wastewater

Which of the following types and/or sources of wastewaters are generated at the facility?

Audit Execution
Process wastewater Yes No

GSCP Reference Environmental Summary of Findings and Corrective Actions

(i.e. water that comes into contact
with the process or product)

Non-contact water Yes No

(i.e. heat exchanged cooling water)

Sanitary wastewater Yes No

Audit Outputs
(i.e. domestic wastewater)

GSCP Reference Environmental Audit Checks

Surface water Yes No
(i.e. storm water run-off/
rainwater run-off)

Are there any of the following on-site:

Glossary
Oil or petrol interceptors Yes No N/A

Septic tanks Yes No N/A

Appendices

Wastewater lagoons Yes No N/A

GSCP Reference Environmental Alert Notification

Soakaways? Yes No N/A

Is there a wastewater treatment Yes No N/A

plant on-site?
If yes, which type of wastewater
treatment (biological, chemical..)?

Are any discharges subject to permit/ Yes No N/A

consent by local or state authorities?
If yes, please provide details

…
Global Social Compliance Programme_11
 GSCP Reference Environmental Audit Report
GSCP Reference Environmental Self Assessment Questionnaire
introduction

Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

Environmental Audit Process & Methodology Reference Tools - november 2010

…
Risk Assessment System

Emissions to air

Does the employment site generate Yes No N/A

emissions to air?
GSCP Reference Environmental Supplementary Audit Information

If yes, please describe

Audit Request

Is the facility subject to any licenses Yes No N/A

GSCP Reference Environmental Pre-Audit Employment Site Profile

for atmospheric emissions?

Are there abatement or pollution Yes No N/A

prevention devices (e.g. filters,
scrubbers) on point source emissions
to air?
Preparation

If so, please describe the abatement

techniques employed at the site

Are any materials burnt or incinerated Yes No N/A

Audit Execution

on site?
GSCP Reference Environmental Summary of Findings and Corrective Actions

Does the site use any ozone-depleting Yes No N/A

substances in equipment or processes
on site?
If yes, please describe
Audit Outputs

Waste management
GSCP Reference Environmental Audit Checks

Please list the main hazardous wastes

generated on-site
Glossary

Please list the main non-hazardous

wastes generated on-site
Appendices

Is the facility subject to any licences, Yes No

permits or similar for waste handling,
GSCP Reference Environmental Alert Notification

storage, treatment or disposal?

Are wastes treated in any way Yes No

on site (e.g. incineration, burning,
on-site lagoons)?
If yes, please describe

12_Global Social Compliance Programme

 GSCP Reference Environmental Audit Report
GSCP Reference Environmental Self Assessment Questionnaire

introduction
Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile
Environmental Audit Process & Methodology Reference Tools - november 2010

Risk Assessment System

Have any of these activities been Yes No
carried out in the past?
If yes, please describe

GSCP Reference Environmental Supplementary Audit Information

Are wastes disposed to landfill Yes No
on site and/or has on-site dumping

Audit Request
taken place in the past?

GSCP Reference Environmental Pre-Audit Employment Site Profile

If yes, please provide details

Does the on-site disposal facility Yes No

accept waste from other sources?

Preparation
If yes, please provide details

What wastes, if any, are recycled?

Audit Execution
GSCP Reference Environmental Summary of Findings and Corrective Actions
Hazardous materials

Are any radioactive materials used Yes No N/A

on-site?

Audit Outputs
Are any wastes generated on-site Yes No N/A
which contain radioactive materials

GSCP Reference Environmental Audit Checks

How are radioactive materials
disposed of?

Glossary
Is asbestos present on-site? Yes No N/A

Has an asbestos survey ever been Yes No N/A

carried out?
Appendices

Have asbestos materials been Yes No N/A

removed from site historically?
GSCP Reference Environmental Alert Notification

Is asbestos used in site products? Yes No N/A

Are any CMR materials (Carcinogenic, Yes No N/A

Mutagenic, Toxic to Reproduction)
used?

Global Social Compliance Programme_13

 GSCP Reference Environmental Audit Report
GSCP Reference Environmental Self Assessment Questionnaire
introduction

Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

Environmental Audit Process & Methodology Reference Tools - november 2010

…
Risk Assessment System

Complaints and enforcement

Have neighbours or the public complained about nuisance/visual impact from any of the following:
GSCP Reference Environmental Supplementary Audit Information

Noise Yes No

Site aesthetics Yes No

Audit Request

Lighting at night Yes No

GSCP Reference Environmental Pre-Audit Employment Site Profile

Litter Yes No

Waste materials storage Yes No

Preparation

Dust Yes No

Vehicle movements Yes No

Other (describe) Yes No

Audit Execution

If yes, please provide details

GSCP Reference Environmental Summary of Findings and Corrective Actions

Are there any regulatory enforcement Yes No

actions or prosecutions outstanding
which relate to the above?
If yes, please provide details
Audit Outputs

GSCP Reference Environmental Audit Checks

…
Glossary
Appendices

GSCP Reference Environmental Alert Notification

14_Global Social Compliance Programme

 GSCP Reference Environmental Audit Report
GSCP Reference Environmental Self Assessment Questionnaire

introduction
Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile
Environmental Audit Process & Methodology Reference Tools - november 2010

Risk Assessment System

Soil and groundwater contamination

Is there soil and/or groundwater Yes No

contamination present on-site?

GSCP Reference Environmental Supplementary Audit Information

If yes, please provide details

Audit Request
Have any intrusive investigations been Yes No

GSCP Reference Environmental Pre-Audit Employment Site Profile

performed?
If yes, please provide details

Are there potential sources of soil Yes No

Preparation
and/or groundwater contamination
from neighbouring properties?
If yes, please describe

Audit Execution
Are regulatory authorities aware Yes No

GSCP Reference Environmental Summary of Findings and Corrective Actions

of any contamination on-site?
If yes, please provide details

Has the facility carried out Yes No

(or are there plans to undertake)

Audit Outputs
any site remediation or clean-up
programme?

GSCP Reference Environmental Audit Checks

If yes, please provide details

Glossary
Appendices
GSCP Reference Environmental Alert Notification

Global Social Compliance Programme_15

 GSCP Reference Environmental Audit Report
GSCP Reference Environmental Self Assessment Questionnaire
introduction

Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

Environmental Audit Process & Methodology Reference Tools - november 2010
Risk Assessment System

3.2 Details of previous environmental audits and outcomes

This section provides the audit history of the employment site. This information helps determine the type of audit required and
whether a current audit report can be shared.
GSCP Reference Environmental Supplementary Audit Information

3.2 Employment Site Previous Environmental Audits and Outcomes

Has your employment site previously been Yes No

Audit Request

audited in relation to environmental issues?

GSCP Reference Environmental Pre-Audit Employment Site Profile

If yes, please provide details of previous audits: Date of audit Code or standard Auditing company/
audited against organisation
Preparation

Would you be prepared to share previous Yes No

audit reports and, improvement/action plans
conducted for other customers?
Audit Execution

Have any previous corrective actions been Yes No

GSCP Reference Environmental Summary of Findings and Corrective Actions

completed?

Please detail outstanding corrective actions Issue found Corrective Timescale Person
and your expected completion date? action responsible
Audit Outputs

GSCP Reference Environmental Audit Checks

Glossary
Appendices

GSCP Reference Environmental Alert Notification

16_Global Social Compliance Programme

 GSCP Reference Environmental Audit Report
GSCP Reference Environmental Self Assessment Questionnaire

introduction
Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile
Environmental Audit Process & Methodology Reference Tools - november 2010

Risk Assessment System

4. Subcontracting

GSCP Reference Environmental Supplementary Audit Information

4.1 Products/processes subcontracted overview
The pre-audit employment site profile should detail the following information on the products and/or processes that are

Audit Request
subcontracted by the employment site:

GSCP Reference Environmental Pre-Audit Employment Site Profile

4.1 Products/Processes Subcontracted

List any production or processes sub-contracted:

Preparation
Subcontractor details: Please complete the table below for each process subcontracted. Add more tables as required.

Subcontracted Process:
Process 1
Products involved:

Audit Execution
GSCP Reference Environmental Summary of Findings and Corrective Actions
No. of subcontracting companies:

Is the concern for the environment part of the subcontractors Yes No

selection criteria?

Have you audited these contractors? Yes No

Audit Outputs
If yes, against which code of conduct/requirements?

GSCP Reference Environmental Audit Checks

Subcontracted Product:
Process 2
Process:

Glossary
No. of subcontracting companies:

Have you audited these contractors? Yes No

Appendices

Subcontracted Product:
Process 3
Process:
GSCP Reference Environmental Alert Notification

No. of subcontracting companies:

Have you audited these contractors? Yes No

Global Social Compliance Programme_17

 GSCP Reference Environmental Audit Report
GSCP Reference Environmental Self Assessment Questionnaire
introduction
Risk Assessment System

Appendix 3
GSCP Reference
GSCP Reference Environmental Supplementary Audit Information

Environmental Audit Checks

Audit Request

GSCP Reference Environmental Pre-Audit Employment Site Profile

This tool forms part of the GSCP set of reference tools The reference AUDIT CHECKS have been designed to provide
designed to provide a common interpretation of local and auditors with the minimum requirements regarding audit
Preparation

international environmental standards and requirements and methodology and evidence gathering. The audit checks are
environmental reference codes (if available and applicable). structured around the 11 Performance Areas and include
The Environmental Reference Requirements reflect a guidance on:
common understanding of good environmental practice and
• physical employment site inspection;
are applicable to all raw material processing, agricultural,
manufacturing and logistics sites in the supply chain. The • employment site procedures and processes;
Audit Execution

Environmental Reference Requirements provide a model

• interviews;
GSCP Reference Environmental Summary of Findings and Corrective Actions

for a site in the supply chain to demonstrate continuous

improvement in its environmental performance from basic • document checks.
compliance to leading-edge performance (across three
defined ‘levels’ for eleven different performance areas). This document is not intended as a checklist but as a list of
checks that should be used as guidance by auditors whilst
The Reference tools on Environmental Audit Process not limiting audit activities.
GSCP Reference Environmental Audit Checks

and Methodology are based on the GSCP Environmental

For your reference, you can make a note when a particular
Audit Outputs

Reference Requirements but can be adopted and tailored to

other codes of environmental practice. point has been noted or question asked by ticking the box
down the left hand side. Where a particular requirement
is being met you can also make note of this. Also, you can
modify its format and layout to better suit your working
methodology, e.g. by adding dedicated pages for note-taking.
Glossary
Appendices

GSCP Reference Environmental Alert Notification

01_Global Social Compliance Programme

 Audit Checks
1. Environmental management system
Employment site requirements at each performance level:
Level 1:
1. Understanding and awareness of significant environmental aspects and impacts (negative and positive)
2. Understanding and awareness of applicable legal requirements
3. Mechanism to remain up-to-date with applicable local legal requirements
4. Basic management controls in place
5. Member of management responsible for coordination of environmental management activities
Level 2:
6. Environmental Management System (EMS) is established, documented, implemented, maintained and continually reviewed/improved
7. The EMS includes:
a. Environmental Policy
b. Planning: environmental risk assessment, setting objectives and targets
c. Implementation and operation: operational procedures; adequate training; documentation and its control
Appendix 3: GSCP Reference Environmental Audit Checks

d. Checking: monitoring and measurement, audit and inspections

e. Management Review
8. Information on environmental performance is made available to appropriate internal and external stakeholders (please refer to the guidance section for detailed
Environmental Audit Process & Methodology Reference Tools - november 2010

definition)
Level 3:
9. Forward looking environmental strategy to drive leading practice
10. Environmental management and environmental performance targets are designed to improve or sustain the environment and local ecosystem, or global when
appropriate
11. Proactive engagement with relevant stakeholders to achieve significant performance improvement
12. Where relevant, commitment to voluntary standards

The following checks are intended as guidance and should not limit audit activities.

Is this performance area applicable to the employment site? Yes No

If yes, please complete the following table. If no, please proceed to the next Performance Area.

Global Social Compliance Programme_02

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
…
Evidence Gathering on Environmental Management System Notes

1.1 Physical employment site inspection

LEVEL 1

❒ Based on observations, the site has identified the significant impacts and aspects associated with the employment site

❒ Procedures that have been established to manage site aspects and impacts are being followed

1.2 Employment site procedures and processes

LEVEL 1

❒ Environmental management policies and procedures are in place (e.g. written policies and procedures, employee

03_Global Social Compliance Programme

handbook, induction training, etc.)

❒ The environmental management system includes a formal mechanism to remain up-to-date with applicable local legal
requirements (e.g. legal/regulatory register)

❒ The environmental management system outlines a member of management responsible for the coordination
of environmental management activities and outlines their roles and responsibilities

❒ Environmental management policies and procedures consider the significant aspects and impacts (negative
and positive) associated with the employment site

1.3 Interviews

Interviews with management confirm the following:

LEVEL 1

❒ Management is aware of, and understands, the significant aspects and impacts (negative and positive) associated
with the employment site

❒ Management is aware of laws and regulations concerning environmental management

❒ Management describe the basic environmental management controls that have been implemented

❒ Policies and processes regarding environmental management are effectively communicated to workers
Appendix 3: GSCP Reference Environmental Audit Checks
Environmental Audit Process & Methodology Reference Tools - november 2010

…
 …
❒ Management provide the appropriate resources (including assigning a member of management responsible
for coordination of environmental management activities) to ensure that compliance with applicable laws
and regulations is maintained

LEVEL 2

❒ Management actively promotes or endorses environmental management

❒ Information on environmental performance is made available to appropriate internal and external stakeholders

❒ Management demonstrate, where appropriate, improvement in environmental performance

LEVEL 3

❒ Management promote a forward looking strategy to drive leading practice in environmental management

❒ Management understand how environmental management and environmental performance targets are designed
to improve or sustain the environment and local ecosystem, or global when appropriate

❒ The site actively engages with appropriate stakeholders down the value chain to achieve significant performance
improvement
Appendix 3: GSCP Reference Environmental Audit Checks

❒ Management promote a commitment to voluntary standards, where appropriate

Interviews with key workers/other workers used to corroborate worker testimony with document checks
Environmental Audit Process & Methodology Reference Tools - november 2010

and management interviews. They confirm the following:

LEVEL 1

❒ Workers understand how they, and their site’s activities and operations, can impact the environment

❒ Key workers are aware of environmental permit/licence requirements, where applicable

❒ Workers receive training on environmental management issues at induction, where appropriate

❒ Key workers with environmental management responsibilities receive specific training as required

Global Social Compliance Programme_04

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
…
1.4 Document checks

LEVEL 1

❒ Relevant employment site permits and licences that relate to environmental management are available and up to date

❒ Where the employment site is legally required to hold and/or maintain documentation in relation to environmental
management, the documentation is retained on file for the required period of time

❒ An up-to-date environmental policy is available

❒ An up-to-date legal/regulatory register is maintained

❒ Relevant management are assigned with environmental roles and responsibilities and these are documented

05_Global Social Compliance Programme

❒ Procedures that address environmental management issues at the site are made available to relevant employment
site personnel

❒ Training materials (e.g. induction records, training matrix etc.) indicate:

• workers receive training on environmental management issues; and
• key workers receive training applicable to their environmental management roles and responsibilities

LEVEL 2

❒ Significant aspects and impacts have been documented

❒ The Environmental Management System (EMS) has been documented

❒ The EMS includes documented environmental risk assessments, objectives and targets

❒ The EMS, or elements of the EMS, has been audited

❒ Management reviews of the EMS are documented and are available

❒ All personnel (management, workers and their representatives, contractors) are engaged in the management
of environmental issues according to their function.

❒ Communications with internal and/or external stakeholders include discussion around environmental performance

…
Appendix 3: GSCP Reference Environmental Audit Checks
Environmental Audit Process & Methodology Reference Tools - november 2010
 …
LEVEL 3

❒ The employment site has identified environmental management and environmental performance targets designed
to improve or sustain the environment and local ecosystem, or global when appropriate

❒ The employment site has investigated and used, if relevant, alternative water sources with lower ecosystem impact

❒ The employment site has established a forward looking strategy to drive leading practice

❒ The employment site has committed to voluntary standards

❒ Communications with appropriate stakeholders through the value chain show that achieving significant performance
improvement has been discussed
Appendix 3: GSCP Reference Environmental Audit Checks
Environmental Audit Process & Methodology Reference Tools - november 2010

Global Social Compliance Programme_06

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report

2. Energy use, transport and Greenhouse Gases (GHGs)

Employment site requirements at each performance level:

Level 1:
1. Meet legal requirements
2. Relevant, up-to-date permits are held and compliance maintained
3. Tracking of energy consumption/calculation of GHG emissions including fuel use for on-site transport
Level 2:
4. Formal systems and processes in place to manage and audit energy use and GHG emissions as per the site EMS
5. Energy consumption and greenhouse gas emissions (including on-site vehicle emissions) are made available to appropriate internal and external stakeholders
6. Renewable energy use targets and GHG emission reduction targets (normalised) are established/reviewed at least on an annual basis to drive continuous improvement
7. Demonstrable reduction in energy (normalised; please refer to the guidance section for further definition)
8. Targets include on-site vehicle emissions reduction, which are reviewed on an annual basis to drive continuous improvement

07_Global Social Compliance Programme

Level 3:
9. Leading practice mechanisms in place to reduce greenhouse gas (GHG) intensity (for further definition please refer to the guidance section)
10. Use of energy sources with lower GHG intensity
a. Energy consumption level is sustainable within availability of local energy resources
b. Demonstrable achievement of stretching energy and fuel efficiency and GHG emission targets beyond recognised international standard practice
11. Engagement with appropriate stakeholders down the value chain identifying ways to reduce GHG emissions
12. Carbon accounting in business system
13. Specification of the most environmentally efficient combinations of vehicle types, fuels and technologies for distribution fleet
14. Fuel consumption and vehicle emission reduction targets are reviewed on an annual basis to drive continuous improvement for the entire fleet

The following checks are intended as guidance and should not limit audit activities.

Is this performance area applicable to the employment site? Yes No

If yes, please complete the following table. If no, please proceed to the next Performance Area.
Appendix 3: GSCP Reference Environmental Audit Checks
Environmental Audit Process & Methodology Reference Tools - november 2010
 Evidence Gathering on Energy Use, Transport and Greenhouse Gases (GHGs) Notes

2.1 Physical employment site inspection

LEVEL 1

❒ Based on observations, the site has established procedures to manage energy use, transport and greenhouse gases
are being followed (e.g. management of substances, activities etc.)

2.2 Employment site procedures and processes

LEVEL 1

❒ Policies and procedures in relation to energy use, transport and GHG emissions management have been established
and implemented (e.g. written policies and procedures, employee handbook, induction training, etc.)

❒ Formal systems and processes in place to manage and audit energy use and GHG emissions as per the site EMS

2.3 Interviews

Interviews with management confirm the following:

Appendix 3: GSCP Reference Environmental Audit Checks

LEVEL 1
Environmental Audit Process & Methodology Reference Tools - november 2010

❒ Management is aware of laws and regulations concerning energy use, transport and GHG emissions and compliance

❒ Policies and processes regarding energy use, transport and GHG emissions are effectively communicated to workers

❒ Management is aware of how energy consumption and how the calculation of GHG emissions is tracked

❒ Management provide the appropriate resources to ensure that compliance with applicable laws and regulations
is maintained
…

Global Social Compliance Programme_08

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
…
LEVEL 2

❒ Management actively promotes or endorses proactive energy conservation

❒ The management are driving continuous improvement and reviewing the on-site transport reduction emission target
on an annual basis

❒ Management are proactively driving continuous improvement through reviewing renewable energy use and GHG
emission reduction targets on an annual basis

❒ The employment site ensures energy consumption and greenhouse gas emissions (including on-site vehicle emissions)
data is made available to relevant internal and external stakeholders

❒ The employment site demonstrates, where appropriate, improvement in energy use performance and that
it is achieving renewable energy use and GHG emission reduction targets

09_Global Social Compliance Programme

LEVEL 3

❒ For energy sources with lower GHG intensity, management understands the concept of sustainable energy
consumption within availability of local energy resources

❒ Management understand what recognised international standard practice is in relation to energy and fuel efficiency
and GHG emission targets for their sector/geography and have set site targets that exceed those practices

❒ Management are proactively driving continuous improvement in the entire transport fleet through reviewing fuel
consumption and vehicle emission reduction targets on an annual basis

❒ The site actively engages with appropriate stakeholders down the value chain to identify ways to reduce GHG
emissions

❒ Management actively promotes the implementation of leading practice greenhouse gas intensity mechanisms

Interviews with key workers/other workers used to corroborate worker testimony with document checks
and management interviews. They confirm the following:

LEVEL 1

❒ Workers have a general understanding of how they, and their site’s activities and operations, can impact energy use
and greenhouse gas emissions

❒ Key workers are aware of energy use and greenhouse gas emissions permit/licence requirements, where applicable
Appendix 3: GSCP Reference Environmental Audit Checks
Environmental Audit Process & Methodology Reference Tools - november 2010

…
 …
❒ Workers receive training on energy use and greenhouse gas emission issues at induction, where appropriate

❒ Key workers with energy use, transport and greenhouse gas emissions management responsibilities receive specific
training as required

❒ Workers have access to, and understand, energy use, transport and greenhouse gas emissions procedures, where
appropriate

2.4 Document checks

LEVEL 1

❒ Relevant employment site permits and licences that relate to energy use, transport and GHGs are available
and up to date

❒ Where the employment site is legally required to hold and/or maintain documentation in relation to energy use,
transport and GHGs, these are held on file for the required period of time

❒ Procedures that address energy use, transport and GHGs at the site are made available to relevant employment site
personnel

❒ Energy consumption/calculation of GHG emissions including fuel use for on-site transport data is recorded, tracked
Appendix 3: GSCP Reference Environmental Audit Checks

and documented

❒ An inventory of main point sources emissions to air is maintained. The site has also considered the potential for
Environmental Audit Process & Methodology Reference Tools - november 2010

fugitive emissions

❒ Training materials (e.g. induction records, training matrix etc.) indicate:

• workers receive training on energy use, transport and GHG issues; and
• key workers receive training applicable to their energy use, transport and GHGs roles and responsibilities

Global Social Compliance Programme_10

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
…
LEVEL 2

❒ Reviews of on-site vehicle emissions reduction targets undertaken and available

❒ Reviews of renewable energy use targets and GHG emission reduction targets (normalised) undertaken and available

❒ Targets in place to phase-out use of specific types of ODS, such as CFCs, halons, TCE, CCl4 in line with recognised
international standard practice

❒ Provide a short summary as to how the employment site has made demonstrable achievement of reducing energy

❒ Provide a short summary as to how the employment site has made demonstrable achievement of meeting
or exceeding air quality improvement targets (normalised)

LEVEL 3

11_Global Social Compliance Programme

❒ Reviews of fuel consumption and vehicle emission reduction targets are undertaken and are available

❒ The employment site has confirmed that energy consumption levels are sustainable (in relation to the availability
of local energy sources)

❒ The employment site has implemented leading practice mechanisms to reduce GHG intensity

❒ Air quality improvement targets are stretching and are being achieved

❒ Communications with appropriate stakeholders through the value chain show that identifying ways to reduce GHG
emissions have been discussed

❒ Energy and fuel efficiency and GHG emission targets are stretching and are being achieved

❒ The employment site has documented the specifications of the most environmentally efficient combinations of vehicle
types, fuels and technologies for distribution fleet
Appendix 3: GSCP Reference Environmental Audit Checks
Environmental Audit Process & Methodology Reference Tools - november 2010
 3. Water use
Employment site requirements at each performance level:

Level 1:
1. Meet legal requirements
2. Relevant, up-to-date permits are held and compliance maintained
3. Measurement of water consumption is undertaken
Level 2:
4. Formal systems and processes in place to manage and audit water consumption as per the site EMS
5. Water consumption data are made available to relevant internal and external stakeholders
6. Water consumption efficiency targets are reviewed on an annual basis to drive continuous improvement
7. Demonstrable achievement of water efficiency targets (normalised)
Level 3:
8. Where relevant, water consumption level is sustainable within local ecosystem limits and water catchment area
9. Investigation of and use, if relevant, of alternative water sources with lower ecosystem impact
10. Demonstrable achievement of stretching water efficiency targets beyond recognised international standard practice
11. Leading practice water efficiency mechanisms in place, including re-use, recovery and recycling
12. Engagement with appropriate stakeholders down the value chain to improve water efficiency
Appendix 3: GSCP Reference Environmental Audit Checks

The following checks are intended as guidance and should not limit audit activities.
Environmental Audit Process & Methodology Reference Tools - november 2010

Is this performance area applicable to the employment site? Yes No

If yes, please complete the following table. If no, please proceed to the next Performance Area.

Global Social Compliance Programme_12

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
…
Evidence Gathering on Water Use Notes

3.1 Physical employment site inspection

LEVEL 1

❒ Employment site operations and activities observed are in line with legal requirements relating to water use
(including water abstraction permit requirements)

❒ Site water use procedures implemented

❒ No water leaks from water tanks or water pipes are observed

❒ Water consumption meters in place

13_Global Social Compliance Programme

3.2 Employment site procedures and processes

LEVEL 1

❒ Policies and procedures in relation to water use management established and implemented (e.g. written policies and
procedures, employee handbook, induction training, etc.)

❒ Formal systems and processes in place in relation to water use management, as per the site EMS

3.3 Interviews

Interviews with management confirm the following:

LEVEL 1

❒ Management is aware of laws and regulations concerning water use and compliance

❒ Policies and processes regarding water use are effectively communicated to workers

❒ Management provide the appropriate resources to ensure that compliance with applicable laws and regulations
is maintained

LEVEL 2
Appendix 3: GSCP Reference Environmental Audit Checks

❒ Management actively promotes or endorses proactive water conservation

Environmental Audit Process & Methodology Reference Tools - november 2010

…
 …
❒ Management are proactively driving continuous improvement through reviewing water consumption efficiency
targets on an annual basis

❒ The employment site ensures water consumption data is made available to relevant internal and external
stakeholders

❒ The employment site demonstrates, where appropriate, improvement in water use and performance and that
it is achieving water efficiency targets

LEVEL 3

❒ Management understands the concept of sustainable water consumption within the local ecosystem limits and water
catchment area

❒ Management actively investigate and uses, if appropriate, alternative water sources with lower ecosystem impact

❒ Management understand what recognised international standard practice is in relation to setting water efficiency
targets for their sector/geography and have set site targets that exceed those practices

❒ The site actively engages with appropriate stakeholders down the value chain to improve water efficiency

❒ Management actively promotes the implementation of leading practice water efficiency mechanisms including,
Appendix 3: GSCP Reference Environmental Audit Checks

e.g. re-use, recovery and recycling

Interviews with key workers/other workers used to corroborate worker testimony with document checks
Environmental Audit Process & Methodology Reference Tools - november 2010

and management interviews. They confirm the following:

LEVEL 1

❒ Workers understand how they, and their site’s activities and operations, can impact water use

❒ Key workers are aware of water use/consumption permit/licence requirements, where applicable

❒ Workers receive training on water use issues at induction, where appropriate

❒ Key workers with water use/consumption management responsibilities receive specific training as required

❒ Workers have access to, and understand, water use procedures, where appropriate

Global Social Compliance Programme_14

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
…
3.4 Document checks

LEVEL 1

❒ Relevant employment site permits and licences that relate to water use are available and up to date

❒ Where the employment site is legally required to hold and/or maintain documentation in relation to water use/
consumption, the documentation is retained on file for the required period of time

❒ Monitoring results for water consumption are available and maintained

❒ Procedures that address water use issues at the site are made available to relevant employment site personnel

❒ Training materials (e.g. induction records, training matrix etc.) indicate:

• workers receive training on water use issues; and

15_Global Social Compliance Programme

• key workers receive training applicable to their water use management roles and responsibilities

LEVEL 2

❒ Reviews of water consumption efficiency targets are undertaken and are available

❒ The employment site has made demonstrable achievement of meeting or exceeding water efficiency targets (normalised)

LEVEL 3

❒ Site has identified whether water use/consumption is sustainable (in relation to the local ecosystem limits and water
catchment area)

❒ Site has investigated and used, if relevant, alternative water sources with lower ecosystem impact

❒ Site has implemented leading practice mechanisms to promote reducing water use/consumption

❒ Water efficiency targets are stretching and are being achieved

❒ Communications with appropriate stakeholders through the value chain show that water efficiency has been discussed
Appendix 3: GSCP Reference Environmental Audit Checks
Environmental Audit Process & Methodology Reference Tools - november 2010
 4. Wastewater/effluent
Employment site requirements at each performance level:
Level 1:
1. Meet legal requirements
2. Relevant, up-to-date permits are held and compliance maintained
3. Drainage plan in place with a general understanding of wastewater flow direction and discharge points
4. Identification of the contaminants, their flow direction and potential impact
Level 2:
5. Formal systems and processes in place to manage wastewater effluent as per the site EMS
6. Basic on-site wastewater treatment in place to achieve improvements in wastewater quality or connection to off-site wastewater treatment system
7. Regular wastewater quality testing/ monitoring is undertaken to ensure ongoing compliance with permitted effluent limits and as per the site’s EMS
8. Wastewater quality data are made available to relevant internal and external stakeholders
9. Wastewater quality and volume improvement targets are reviewed on an annual basis to drive continuous improvement
10. Demonstrable improvement in wastewater quality
Level 3:
11. Wastewater effluent quality and discharge volume are sustainable in the context of local receptors and ecosystem limits
12. Leading practice wastewater treatment in place
Appendix 3: GSCP Reference Environmental Audit Checks

13. Leading practice mechanisms in place to improve quality of wastewater discharged to local environment, including reuse of grey water
14. Demonstrable achievement of stretching wastewater effluent quality improvement and volume reduction targets (normalised) beyond recognised international
standard practice
Environmental Audit Process & Methodology Reference Tools - november 2010

15. Engagement with appropriate stakeholders down the value chain to improve wastewater effluent quality

The following checks are intended as guidance and should not limit audit activities.

Is this performance area applicable to the employment site? Yes No

If yes, please complete the following table. If no, please proceed to the next Performance Area.

Global Social Compliance Programme_16

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
…
Evidence Gathering on Wastewater / Effluent Notes

4.1 Physical employment site inspection

LEVEL 1

❒ Based on observations, sources of wastewater generated across the employment site have been identified

❒ Based on observation, confirmed that wastewaters are not discharging direct to unprotected ground and are directed
to a drainage system

❒ Based on observation, sumps/pits receiving wastewater are in good condition and of sound integrity

❒ Is wastewater/effluent directed to a wastewater/effluent treatment plant or undergoes treatment prior to discharge

17_Global Social Compliance Programme

❒ Surface water/stormwater drains are free from contamination and blockages

❒ Procedures established to manage wastewater/wastewater discharges are being followed (e.g. management
of wastewater, activities etc.)

❒ No spills or leaks to the environment observed

LEVEL 2

❒ Check whether basic on-site wastewater treatment is in place to achieve improvements in wastewater quality
or connection to off-site wastewater treatment system

4.2 Employment site procedures and processes

LEVEL 1

❒ Policies and procedures in relation to wastewater/effluent management have been established and implemented
(e.g. written policies and procedures, employee handbook, induction training, etc.)

❒ Regular wastewater quality testing/monitoring is undertaken to ensure ongoing compliance with permitted effluent
limits and as per the site’s EMS

…
Appendix 3: GSCP Reference Environmental Audit Checks
Environmental Audit Process & Methodology Reference Tools - november 2010
 …
4.3 Interviews

Interviews with management confirm the following:

LEVEL 1

❒ Management is aware of laws and regulations concerning wastewater/effluent discharge compliance

❒ Policies and processes regarding wastewater/effluent are effectively communicated to workers

❒ Management describe how the employment site identifies the contaminants, their flow direction and potential
impact in relation to wastewater/effluent discharges from the employment site

❒ Management provide the appropriate resources to ensure that compliance with applicable laws and regulations
is maintained

LEVEL 2

❒ Management actively promotes or endorses proactive wastewater quality and management

❒ Management are proactively driving continuous improvement through reviewing wastewater quality and volume
improvement targets on an annual basis
Appendix 3: GSCP Reference Environmental Audit Checks

❒ The employment site ensures wastewater quality data is made available to relevant internal and external stakeholders

❒ The employment site demonstrates, where appropriate, improvement in wastewater quality and performance
Environmental Audit Process & Methodology Reference Tools - november 2010

and that it is achieving wastewater quality targets

LEVEL 3

❒ Management understands the concept of sustainable wastewater effluent quality and discharge within the local
ecosystem limits and local receptors

❒ Management understand what recognised international standard practice is in relation to setting wastewater effluent
quality improvement targets and volume reduction targets (normalised) for their sector/geography and have set site
targets that exceed those practices

❒ Management understand leading practice wastewater treatment and this has been implemented at the site

❒ The site actively engages with appropriate stakeholders down the value chain to improve wastewater effluent quality

❒ Management actively promotes the implementation of leading practice mechanisms to improve the quality
of wastewater discharged to local environment, including reuse of grey water

Global Social Compliance Programme_18

…
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
…
Interviews with key workers/other workers used to corroborate worker testimony with Document checks
and management interviews. They confirm the following:

LEVEL 1

❒ Workers understand how they, and their site’s activities and operations, can impact wastewater/effluent quality
and discharge volumes

❒ Key workers are aware of wastewater/effluent permit/licence requirements, where applicable

❒ Workers receive training on wastewater/effluent issues at induction, where appropriate

❒ Key workers with wastewater/effluent management responsibilities receive specific training as required

❒ Workers have access to, and understand, wastewater/effluent procedures, where appropriate

19_Global Social Compliance Programme

4.4 Document checks

LEVEL 1

❒ Relevant employment site permits and licences that relate to wastewater/effluent discharge are available and up to date

❒ Where the employment site is legally required to hold and/or maintain documentation in relation to wastewater/
effluent, the documentation is retained on file for the required period of time

❒ Procedures that address wastewater/effluent issues at the site are made available to relevant employment site personnel

❒ The employment site has identified and documented the contaminants, their flow direction and potential impact
associated with wastewater/effluent discharges leaving the site

❒ An up-to-date drainage plan of the employment site is available and confirms a general understanding of wastewater
flow direction and discharge points

❒ Training materials (e.g. induction records, training matrix etc.) indicate:

• Workers receive training on wastewater/effluent issues; and
• Key workers receive training applicable to their wastewater/effluent management roles and responsibilities

…
Appendix 3: GSCP Reference Environmental Audit Checks
Environmental Audit Process & Methodology Reference Tools - november 2010
 …
LEVEL 2

❒ Reviews of wastewater quality and volume improvement targets are undertaken and are available

❒ Regular wastewater quality testing/monitoring results are available

❒ The employment site has made demonstrable achievement of meeting or exceeding wastewater quality and volume
improvement targets (normalised)

LEVEL 3

❒ The employment site has identified whether wastewater effluent quality and discharge volume is sustainable
(in relation to the local ecosystem and local receptors limits)

❒ The site has implemented leading practice mechanisms to promote reducing water use/consumption

❒ Wastewater effluent quality improvement and volume reduction targets are stretching and are being achieved

❒ Communications with appropriate stakeholders through the value chain show that wastewater effluent quality
has been discussed
Appendix 3: GSCP Reference Environmental Audit Checks
Environmental Audit Process & Methodology Reference Tools - november 2010

Global Social Compliance Programme_20

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report

5. Emissions to air
Employment site requirements at each performance level:
Level 1:
1. General: Meet legal requirements (including monitoring)
2. General: Relevant, up-to-date permits are held and compliance maintained
3. General: An inventory of main point source emissions to air is maintained and site has considered potential for fugitive emissions
4. Ozone Depleting Substances: Meet legal requirements
5. Ozone Depleting Substances: Relevant, up-to-date permits are held and compliance maintained
6. Ozone Depleting Substances: An inventory of ozone-depleting substances (ODS) is maintained
7. Ozone Depleting Substances: Regular maintenance of ODS containing equipment
Level 2:
8. General: Formal systems and processes in place to manage emissions to air as per the site EMS

21_Global Social Compliance Programme

9. General: Regular air emissions quality testing/monitoring is undertaken to ensure ongoing compliance with permitted limits
10. General: Air emissions quality data are made available to relevant internal and external stakeholders
11. General: Air quality improvement targets are reviewed on an annual basis to drive continuous improvement
12. General: Demonstrable reduction in emissions to air (normalised)
13. Ozone Depleting Substances: Proactive ODS leak detection and maintenance of ODS-containing equipment
14. Ozone Depleting Substances: Targets in place to phase-out use of specific types of ODS, such as CFCs, halons, TCE, CCl4 in line with recognised international standard practice
15. Ozone Depleting Substances: Demonstrable reduction, control and substitution of ODS
Level 3:
16. General: Emissions to air are sustainable within local ecosystem limits
17. General: Leading practice abatement technologies in place to minimise emissions to air or efforts to reduce emissions at source
18. General: Demonstrable achievement of stretching air quality improvement targets beyond recognised international standard practice
19. General: Engagement with appropriate stakeholders down the value chain to reduce emissions to air
20. General: Additional and proactive emissions monitoring performed
21. Ozone Depleting Substances: Complete phase-out of all ODS (beyond legal requirements)

The following checks are intended as guidance and should not limit audit activities.

Is this performance area applicable to the employment site? Yes No

If yes, please complete the following table. If no, please proceed to the next Performance Area.
Appendix 3: GSCP Reference Environmental Audit Checks
Environmental Audit Process & Methodology Reference Tools - november 2010
 Evidence Gathering on Emissions to Air notes

5.1 Physical employment site inspection

LEVEL 1

❒ Based on observation, site has identified point and fugitive sources of emissions to air

❒ Based on observation, no abnormal emissions to air are discernible across the site and at the site perimeter

❒ Based on observation, site has identified that equipment present on-site that has the potential to contain ozone-
depleting substances (e.g. chillers, air conditioning units, etc.)

❒ Procedures established to manage emissions to air and ozone-depleting substances are being followed
(e.g. management of emission sources, equipment, activities etc.)

❒ Emissions to air abatement equipment has been checked to ensure that it is in appropriate working order

❒ Equipment likely to contain ozone-depleting substances has been checked to ensure that it is in appropriate working order

5.2 Employment site procedures and processes

Appendix 3: GSCP Reference Environmental Audit Checks

LEVEL 1
Environmental Audit Process & Methodology Reference Tools - november 2010

❒ Policies and procedures in relation to emissions to air and ozone-depleting substances have been established
and implemented (e.g. written policies and procedures, employee handbook, induction training, etc.)

❒ Formal systems and processes in place to manage emissions to air as per the site EMS

Global Social Compliance Programme_22

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
…
5.3 Interviews

Interviews with management confirm the following:

LEVEL 1

❒ Management is aware of laws and regulations (including monitoring requirements) concerning emissions to air
compliance

❒ Management is aware of laws and regulations (including monitoring requirements) concerning ozone-depleting
substances compliance

❒ Policies and processes regarding emissions to air and ozone-depleting substances are effectively communicated
to workers

❒ Management provide the appropriate resources to ensure that compliance with applicable laws and regulations
is maintained

23_Global Social Compliance Programme

LEVEL 2

❒ Management actively promotes or endorses proactive emissions to air management

❒ Management actively promotes or endorses proactive ODS management (including leak detection and maintenance)

❒ Management are proactively driving continuous improvement through reviewing air quality improvement targets
on an annual basis

❒ The employment site ensures air emissions quality data is made available to relevant internal and external stakeholders

❒ The employment site demonstrates, where appropriate, a reduction in emissions to air

❒ The employment site demonstrates, where appropriate, reduction, control and substitution of ODS targets

LEVEL 3

❒ Management understands the concept of sustainable emissions to air within the local ecosystem limits

❒ Management understand what recognised international standard practice is in relation to setting air quality
improvement targets for their sector/geography and have set site targets that exceed those practices

❒ Management understand leading practice abatement technologies to minimise emissions to air or efforts to reduce
emissions at source and this has been implemented at the site
Appendix 3: GSCP Reference Environmental Audit Checks

❒ The site actively engages with appropriate stakeholders down the value chain to reduce emissions to air
Environmental Audit Process & Methodology Reference Tools - november 2010

…
 …
Interviews with key workers/other workers used to corroborate worker testimony with document checks
and management interviews. They confirm the following:

LEVEL 1

❒ Workers understand how they, and their site’s activities and operations, can impact emissions to air

❒ Key workers are aware of emissions to air and ozone-depleting substances permit/licence requirements, where applicable

❒ Workers receive training on emissions to air and ozone-depleting substances issues at induction, where appropriate

❒ Key workers with emissions to air and ozone-depleting substances management responsibilities receive specific
training as required

❒ Workers have access to, and understand, emissions to air and ozone-depleting substances procedures, where appropriate

5.4 Document checks

LEVEL 1

❒ Relevant employment site permits and licences that relate to emissions to air are available and up to date

❒ Relevant employment site permits and licences that relate to ozone-depleting substances are available and up to date
Appendix 3: GSCP Reference Environmental Audit Checks

❒ Where the employment site is legally required to hold and/or maintain documentation in relation to emissions to air
and ozone-depleting substances, these are held on file for the required period of time
Environmental Audit Process & Methodology Reference Tools - november 2010

❒ Procedures that address emissions to air and ozone-depleting substances at the site are made available to relevant
employment site personnel

❒ An inventory of main point sources emissions to air is maintained. The site has also considered the potential for
fugitive emissions

❒ An inventory of ozone-depleting substances (ODS) is maintained

❒ Regular maintenance records are available for the regular maintenance of ODS containing equipment

❒ Competency records of external ODS servicing contractors are held on file, where required

❒ Training materials (e.g. induction records, training matrix etc.) indicate:

• workers receive training on emissions to air and ODS issues; and
• key workers receive training applicable to their emissions to air and ODS roles and responsibilities

Global Social Compliance Programme_24

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
…
LEVEL 2

❒ Reviews of air quality improvement targets are undertaken and are available

❒ Regular air emissions and quality testing/monitoring results are available

❒ The employment site has demonstrated proactive ODS leak detection and maintenance of ODS-containing equipment,
above legal requirements

❒ Targets are in place to phase-out use of specific types of ODS, such as CFCs, halons, TCE, CCl4 in line with recognised
international standard practice

❒ The employment site has made demonstrable achievement of reducing, controlling and substituting ODSs

❒ The employment site has made demonstrable achievement of meeting or exceeding air quality improvement targets

25_Global Social Compliance Programme

(normalised)

LEVEL 3

❒ The employment site has identified whether emissions to air are sustainable (in relation to the local ecosystem limits)

❒ The employment site has implemented leading practice abatement technologies to minimise emissions to air
or efforts to reduce emissions at source

❒ Air quality improvement targets are stretching and are being achieved

❒ Communications with appropriate stakeholders through the value chain show that reducing emissions to air has been
discussed

❒ The employment site has performed additional and proactive emissions monitoring beyond legal requirements

❒ The employment site has documented the complete phase-out of all ODS (beyond legal requirements)
Appendix 3: GSCP Reference Environmental Audit Checks
Environmental Audit Process & Methodology Reference Tools - november 2010
 6. Waste management
Employment site requirements at each performance level:
Level 1:
1. Meet legal requirements
2. Relevant, up-to-date permits are held and compliance maintained
3. Regular checks that waste contractors have appropriate permits are undertaken
4. Hazardous and non-hazardous waste is segregated and employee awareness and training provided on handling and segregation of wastes
5. Inventory/management/storage/transportation procedures for hazardous waste streams are in place
6. Records of on-site and off-site waste disposal/treatment maintained
7. No on-site waste burning/or uncontrolled waste landfilling is undertaken
Level 2:
8.  Formal systems and processes in place to manage waste generation, storage, transportation and disposal as per the site EMS including waste minimisation audit
and consideration of waste hierarchy principles
9. Evaluation of waste management contractors (suitability, disposal/treatment methods)
10. Engagement with suppliers to identify waste avoidance/reduction/recycling/reuse opportunities
11. Segregation of waste streams in line with recognised international standard practice
12. Monitoring and measurement of waste generated and recycled with data available to relevant internal and external stakeholders
13. Waste reduction and recycling targets are reviewed at least on an annual basis to drive continuous improvement
Appendix 3: GSCP Reference Environmental Audit Checks

14. Demonstrable waste reduction (normalised)

Level 3:
Environmental Audit Process & Methodology Reference Tools - november 2010

15. Waste disposal method and volume is sustainable within local operating environment and availability of waste treatment and disposal facilities
16. Leading practices in place to minimise resource/virgin material use and achieve waste reduction/recycling/energy from waste
17. Demonstrable achievement of stretching waste reduction/recycling targets beyond recognised international standard practice
18. Engagement with appropriate stakeholders down the value chain to identify waste avoidance/reduction/recycling/reuse/energy from waste measures

The following checks are intended as guidance and should not limit audit activities.

Is this performance area applicable to the employment site? Yes No

If yes, please complete the following table. If no, please proceed to the next Performance Area.

Global Social Compliance Programme_26

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
…
Evidence Gathering on Waste Management notes

6.1 Physical employment site inspection

LEVEL 1

❒ Segregation and storage practices are in line with legal requirements

❒ Wastes are being segregated according to hazardous and non-hazardous characteristics

❒ Wastes are being stored in containers applicable to their contents

❒ Waste containers are in good condition

❒ Containers and/or storage areas located externally are covered to prevent rain water ingress

27_Global Social Compliance Programme

❒ All containers of waste are labelled with their contents

❒ Containers of hazardous waste are labelled with their contents and hazard characteristics

❒ Surfaces of waste storage areas are in good condition to prevent spillage or leaking of waste materials

❒ Uncontrolled burning or uncontrolled landfilling activities not undertaken on-site

❒ Waste materials reported as being recycled are being identified and separated for on-site or off-site recycling

❒ Spill response materials/equipment (e.g. granules etc.) are available in close proximity to containers of liquid wastes

❒ Review a number of waste management activities to check whether site waste management procedures are being
implemented

❒ Try to identify the physical location where waste documentation is being stored

❒ Check for evidence of:

• communications/meeting minutes regarding the management of waste are displayed for all workers to see
(e.g. on notice boards)
• waste minimisation programmes

…
Appendix 3: GSCP Reference Environmental Audit Checks
Environmental Audit Process & Methodology Reference Tools - november 2010
 …
6.2 Employment site procedures and processes

LEVEL 1

❒ Policies and procedures regarding waste management is in place (e.g. written policies and procedures, employee
handbook, induction training, etc.)

❒ Formal systems and processes are in place to manage waste generation, storage, transportation, and disposal
as per the site EMS

6.3 Interviews

Interviews with management confirm the following:

LEVEL 1

❒ Management is aware of laws and regulations concerning waste management and compliance

❒ Policies and procedures regarding waste management is effectively communicated to workers

❒ Management provide the appropriate resources to ensure compliance with applicable laws and regulations
is maintained
Appendix 3: GSCP Reference Environmental Audit Checks

❒ Management have nominated key workers to undertake regular checks on waste contractor permits/licences
Environmental Audit Process & Methodology Reference Tools - november 2010

LEVEL 2

❒ A nominated person has evaluated the suitability and disposal/treatment methods of waste management contractors

❒ The employment site engages with suppliers to identify waste avoidance/recycling/reuse opportunities

❒ Management facilitate annual reviews of waste reduction and recycling targets

Global Social Compliance Programme_28

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
…
LEVEL 3

❒ Management understand the concept of sustainable waste disposal methods and whether current site waste
generation is sustainable

❒ Management is actively promoting or endorsing site implementation of leading practices in relation to, for example,
minimising virgin material use and waste generation and increasing the percentage of site waste materials that are
recycled and/or the generation of energy from waste

❒ Management understand what recognised international standard practice is in relation to waste reduction/recycling
for their sector/geography and have set site targets that exceed those practices

Interviews with key workers/other workers used to corroborate worker testimony with Document checks
and management interviews. They confirm the following:

LEVEL 1

29_Global Social Compliance Programme

❒ Key workers are aware of waste management permit/licence requirements, where applicable

❒ Workers receive training on waste segregation and storage requirements at induction

❒ Key workers with waste management responsibilities receive specific training on waste management activities

❒ Workers have access to, and understand, hazardous waste inventory/management/storage/disposal procedures

6.4 Document checks

LEVEL 1

❒ Relevant employment site waste permits and licences are available

❒ Documentation of off-site waste disposal/treatment is completed accurately and contains all relevant information
as required by applicable laws and regulations

❒ Waste documentation is retained on file for the minimum legal requirement

❒ Regular checks that waste contractors have appropriate permits/licences have been undertaken

❒ Inventory/management/storage/transportation procedures are in place and are made available to relevant

employment site personnel
Appendix 3: GSCP Reference Environmental Audit Checks
Environmental Audit Process & Methodology Reference Tools - november 2010

…
 …
❒ Training materials (e.g. induction records, training matrix etc.) indicate:
• workers receive training on waste handling, segregation and storage requirements; and
• key workers receive training applicable to their waste management roles and responsibilities

LEVEL 2

❒ Waste minimisation audits have been undertaken

❒ The employment site has considered and, where practical, applied the waste hierarchy principles

❒ Audits of waste contractors have been undertaken to determine the suitability and disposal/treatment methods
of waste contractors

❒ Communications with suppliers show that waste avoidance/reduction/recycling/reuse opportunities have been
discussed

❒ Monitoring/measurement data of wastes generated and recycling targets are available

❒ Waste reduction/recycling targets have been documented and are reviewed at least annually

LEVEL 3
Appendix 3: GSCP Reference Environmental Audit Checks

❒ Reviews are undertaken to assess the future waste capacity of receiving treatment/disposal facilities to identify waste
reduction priorities and drive sustainability
Environmental Audit Process & Methodology Reference Tools - november 2010

❒ The employment site has identified whether the disposal methods and volumes of its wastes are sustainable
(in relation to the local operating environment and availability of waste treatment and disposal facilities)

❒ Employment site has implemented leading practice measures to minimise virgin material use and waste generated

❒ The employment site has implemented leading practices in relation to recycling and/or the generation of energy
from waste

❒ Waste reduction/recycling targets are stretching and are being achieved

❒ Communications with stakeholders show that waste avoidance/reduction/recycling/reuse opportunities down

the value chain have been discussed

Global Social Compliance Programme_30

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report

7. Pollution prevention/hazardous and potentially hazardous substances

Employment site requirements at each performance level:
Level 1:
1. Meet legal requirements
2. Compliance with prohibited chemicals list (e.g. for agrichemicals from World Health Organisation, WHO)
3. Relevant, up-to-date permits are held and compliance maintained
4. An inventory of hazardous substances used and stored is maintained together with relevant up-to-date Material Safety Data Sheets (MSDS)
5.  Specific procedures/controls in place for the management/storage/transportation of all hazardous substances, minimising potential for air, water, soil
and groundwater impacts
6. Pollution prevention and response training is delivered to all relevant employees
7. Incidents are notified to the authorities as required by applicable permits/legislation
Level 2:

31_Global Social Compliance Programme

8. Formal systems and processes in place for pollution prevention and to reduce the potential for pollution incidents as per the site EMS
9. Dedicated site emergency response team in place to deal with pollution incidents
10. Regular practice drills are carried out for pollution incidents
11. Targets are reviewed on an annual basis to reduce the use of hazardous substances, minimise associated risks and substitute with non-hazardous alternatives where possible
12. Where relevant, specific pollution prevention mechanisms are considered in agricultural production, including optimisation of agrichemicals input
13. Demonstrable reduction in hazardous substances use (normalised) and minimisation of associated risks, as appropriate
Level 3:
14. ‘Zero pollution incident’ target and policy in place
15. Detailed pollution prevention inspections are conducted
16. Promote the use of non-hazardous and non-toxic alternative substances
17. Demonstrable achievement of stretching hazardous substance reduction / substitution targets beyond recognised international standard practice
18. Engagement with appropriate stakeholders down the value chain to improve hazardous substance use

The following checks are intended as guidance and should not limit audit activities.

Is this performance area applicable to the employment site? Yes No

If yes, please complete the following table. If no, please proceed to the next Performance Area.
Appendix 3: GSCP Reference Environmental Audit Checks
Environmental Audit Process & Methodology Reference Tools - november 2010
 Evidence Gathering on Pollution Prevention/Hazardous and Potentially Hazardous Substances notes

7.1 Physical employment site inspection

LEVEL 1

❒ Hazardous and potentially hazardous substance storage, use, handling, processing and/or disposal are in line
with legal requirements

❒ Bulk containers (including tanks) and pipework containing hazardous and potentially hazardous substances
with the potential to cause pollution are in good condition and of sound integrity

❒ Bulk containers (including tanks) and pipework containing hazardous and potentially hazardous substances
with the potential to cause pollution are labelled, where appropriate

❒ Check, through observation, for the presence and use of prohibited chemicals at the employment site

❒ Relevant up-to-date Material Safety Data Sheets (MSDS) are available in areas where chemicals are being stored/used

❒ Procedures/control established to prevent/reduce the potential for pollution are being followed (e.g. management
of substances, storage, transportation etc.)
Appendix 3: GSCP Reference Environmental Audit Checks

❒ Emergency response and pollution prevention equipment (e.g. spill kits) is available and has been checked to ensure
that it is in appropriate working order
Environmental Audit Process & Methodology Reference Tools - november 2010

❒ No spills or leaks to the environment are observed

❒ Secondary containment/bunds are in good condition and are of sound integrity

7.2 Employment site procedures and processes

LEVEL 1

❒ Policies and procedures in relation to pollution prevention/hazardous and potentially hazardous substances
management have been established and implemented (e.g. written policies and procedures, employee handbook,
induction training, etc.)

❒ Formal systems and processes in place for pollution prevention and to reduce the potential for pollution incidents
as per the site EMS

Global Social Compliance Programme_32

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
…
7.3 Interviews

Interviews with management confirm the following:

LEVEL 1

❒ Where there is the potential for pollution to occur, the employment site has identified this potential

❒ Management is aware of laws and regulations concerning pollution prevention/hazardous and potentially hazardous
substances management and compliance

❒ Management is aware of the prohibited chemicals list (e.g. for agrichemicals from World Health Organisation, WHO)
and compliance with this requirement

❒ Policies and processes regarding pollution prevention/hazardous and potentially hazardous substances management
is effectively communicated to relevant workers

33_Global Social Compliance Programme

❒ Management provide the appropriate resources to ensure compliance with applicable laws and regulations is maintained

LEVEL 2

❒ Measures have been implemented to reduce the potential for pollution to occur at the employment site

❒ Management is actively promoting the implementation of specific pollution prevention mechanisms in agricultural
production, including optimisation of agrichemicals input

❒ Management is actively engaged in promoting and achieving a reduction in hazardous substances use (normalised)
and minimisation of associated risks, as appropriate

LEVEL 3

❒ Management is actively promoting the use of non-hazardous and non-toxic alternative substances

Interviews with key workers/other workers used to corroborate worker testimony with Document checks
and management interviews. They confirm the following:

LEVEL 1

❒ Workers understand how they, and their site’s activities and operations, can cause pollution

❒ Key workers are aware of pollution prevention/hazardous and potentially hazardous substances permit/licence
requirements, where applicable
Appendix 3: GSCP Reference Environmental Audit Checks
Environmental Audit Process & Methodology Reference Tools - november 2010

❒ Workers receive training on pollution prevention/hazardous and potentially hazardous substances at induction

…
 …
❒ Relevant workers with responsibilities for the prevention of pollution receive specific training on its prevention
and relevant response in the event of a release

❒ Workers have access to, and understand, pollution prevention/hazardous and potentially hazardous substances
procedures

LEVEL 2

❒ Regular practice drills are carried out for pollution incidents

❒ A dedicated site emergency response team is in place to deal with pollution incidents

7.4 Document checks

LEVEL 1

❒ Relevant employment site permits and licences that relate to pollution prevention/hazardous and potentially
hazardous substances are available and up to date

❒ Where the employment site is legally required to hold and/or maintain documentation in relation to pollution
prevention/hazardous and potentially hazardous substances, the documentation is retained on file for the required
period of time
Appendix 3: GSCP Reference Environmental Audit Checks

❒ Pollution incidents have been notified to the authorities as required by applicable permits/legislation

❒ The employment site has considered and documented all potential pollution scenarios related to the site’s activities
and operations
Environmental Audit Process & Methodology Reference Tools - november 2010

❒ Specific procedures/controls for the management/storage/transportation of all hazardous substances, minimising

potential for air, water, soil and groundwater impacts are made available to relevant employment site personnel

❒ The employment site maintains an inventory of hazardous substances used and stored on-site

❒ The employment site maintains relevant up-to-date Material Safety Data Sheets (MSDS) and these are made available
to employees in the language(s) understood by the majority of employees.

❒ The employment site has considered and documented chemicals used on-site and whether they are on the prohibited
chemicals list

❒ Training materials (e.g. induction records, training matrix etc.) indicate:

• workers receive training on pollution prevention and response; and
• pollution response team members have received appropriate training

Global Social Compliance Programme_34

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report

LEVEL 2

❒ Documented evidence that regular practice drills are carried out for pollution incidents

❒ Improvement actions identified from practice drills have been implemented and closed out

❒ The employment demonstrates a reduction in hazardous substances use (normalised) and minimisation of associated
risks, as appropriate

❒ Hazardous substance use and non-hazardous alternative use performance targets are reviewed annually and reviews
have been documented

❒ The employment site has implemented pollution prevention mechanisms to reduce the potential for pollution
in agricultural production this includies optimisation of agrichemicals input

35_Global Social Compliance Programme

LEVEL 3

❒ A ‘Zero pollution incident’ target and policy is in place and has been documented

❒ Detailed pollution prevention inspections are documented and maintained. Inspections consider all areas
of the employment site where the potential for pollution exists.

❒ The employment site has documented non-hazardous and non-toxic alternative substances that are available

❒ Hazardous substance reduction/substitution performance targets are stretching and are being achieved

❒ Communications show the employment site engages with appropriate stakeholders down the value chain to improve
hazardous substance use

❒ The employment site has implemented leading practice mechanisms to reduce the potential for major incidents
(e.g. process changes etc.)
Appendix 3: GSCP Reference Environmental Audit Checks
Environmental Audit Process & Methodology Reference Tools - november 2010
 8. Major incident management
Employment site requirements at each performance level:
Level 1:
1. Meet legal requirements
2. Relevant, up-to-date permits are held and compliance maintained
3. Site emergency plan in place with detailed guidelines/training for major incident response, as needed and reflecting the risks of activities undertaken on-site
4. Emergency response plan communicated to local authorities, emergency services and local communities, as required
Level 2:
5. Formal systems and processes in place to manage emergency response as per the site EMS
6. Reduction in potential occurrence and impacts of major incidents (e.g. explosions, fires, major spills etc.)
7. Regular Quantitative Risk Assessment (QRA) reviews
8. Major incidents reported to relevant stakeholders
9. Dedicated site emergency response team in place
10. Regular practice drills are carried out for all emergency scenarios
Level 3:
11. ‘Zero major incident’ target and policy in place
12. Proactive engagement with local community to ensure awareness of risks of major incidents and emergency response procedures
Appendix 3: GSCP Reference Environmental Audit Checks

13. Local community is involved in site’s emergency response drill and has been contacted by the emergency response team, as relevant
14. Leading practice mechanisms in place to reduce risk of major incidents e.g. process changes
Environmental Audit Process & Methodology Reference Tools - november 2010

The following checks are intended as guidance and should not limit audit activities.

Is this performance area applicable to the employment site? Yes No

If yes, please complete the following table. If no, please proceed to the next Performance Area.

Global Social Compliance Programme_36

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
…
Evidence Gathering on Major Incident Management notes

8.1 Physical employment site inspection

LEVEL 1

❒ Confirm, through observation, whether substances used and/or activities undertaken at site have the potential
to cause major incidents

❒ Hazardous substance storage, use, handling, processing and/or disposal are in line with legal requirements

❒ Ensure hazardous substances are being segregated to prevent potential major incidents from occurring

❒ Bulk containers (including tanks) and pipework containing substances with the potential to cause a major incident
are in good condition and of sound integrity

37_Global Social Compliance Programme

❒ Bulk containers (including tanks) and pipework containing substances with the potential to cause a major incident
are labelled, where appropriate

❒ Check whether procedures established to prevent/reduce the potential for a major incident are being followed
(e.g. management of substances, activities etc.)

❒ Emergency response equipment is available and has been checked to ensure that it is in appropriate working order

❒ Emergency response plan and arrangements (including site/emergency service contact details) are displayed
or are available throughout the employment site

❒ No spills or leaks to the environment are observed

❒ Review neighbouring properties/operations and confirm whether there is the potential for a major incident that could
impact the employment site (this would be an observation rather than a compliance finding)

8.2 Employment site procedures and processes

LEVEL 1

❒ Policies and procedures to prevent/reduce the potential for a major incident have been established and implemented
(e.g. written policies and procedures, employee handbook, induction training etc.)

❒ Policies and procedures for emergency response have been established and implemented (e.g. written policies
Appendix 3: GSCP Reference Environmental Audit Checks

and procedures, employee handbook, induction training etc.)

Environmental Audit Process & Methodology Reference Tools - november 2010

…
 …
LEVEL 2

❒ Formal systems and processes are in place to prevent/reduce the potential for major incidents as per the site EMS

❒ Formal systems and processes are in place for emergency response as per the site EMS

8.3 Interviews

Interviews with management confirm the following:

LEVEL 1

❒ Where there is the potential for a major incident to occur, confirm whether the employment site has identified
this potential

❒ Management is aware of laws and regulations concerning major incident management and compliance

❒ Policies and processes regarding major incident management is effectively communicated to workers

❒ Management provide the appropriate resources to ensure compliance with applicable laws and regulations
is maintained
Appendix 3: GSCP Reference Environmental Audit Checks

LEVEL 2
Environmental Audit Process & Methodology Reference Tools - november 2010

❒ Measures have been implemented to reduce the potential occurrence and severity of major incidents
at the employment site

❒ Management is actively engaged in promoting and achieving a reduction in the potential occurrence and impacts
of major incidents

LEVEL 3

❒ Management is actively promoting the implementation of leading practice mechanisms in relation to reducing risk
of major incidents

Global Social Compliance Programme_38

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
…
Interviews with key workers/other workers used to corroborate worker testimony with Document checks
and management interviews. They confirm the following:

LEVEL 1

❒ Workers understand how they, and their site’s activities and operations, can cause major incidents

❒ Key workers are aware of major incident and emergency response permit/licence requirements, where applicable

❒ Workers receive training on major incident prevention and emergency response at induction

❒ Key workers with responsibilities for the prevention of major incidents receive specific training on their prevention
and relevant emergency response

❒ Workers have access to, and understand, major incident prevention and emergency response procedures

39_Global Social Compliance Programme

LEVEL 2

❒ A dedicated site emergency response team is in place

8.4 Document checks

LEVEL 1

❒ Relevant employment site permits and licences that relate to major incident prevention and emergency response
are available and up to date

❒ Where the employment site is legally required to hold and/or maintain documentation in relation to the prevention
of or response to major incidents, the documentation is retained on file for the required period of time

❒ The employment site has considered and documented all emergency scenarios related to the site’s activities
and operations

❒ Major incident prevention and emergency response procedures are made available to relevant employment site
personnel

❒ The employment site emergency plan reflects the risks associated with activities undertaken on-site and is maintained
up to date

❒ Documented communication of the emergency response plan to local authorities, emergency services and local
Appendix 3: GSCP Reference Environmental Audit Checks

communities, as required
Environmental Audit Process & Methodology Reference Tools - november 2010

…
 …
❒ Training materials (e.g. induction records, training matrix etc.) indicate:
• workers receive training on major incident prevention and emergency response; and
• emergency response team members have received appropriate training

LEVEL 2

❒ Major incidents have been reported to relevant stakeholders

❒ Documented evidence that regular practice drills are carried out for all emergency scenarios

❒ Improvement actions identified from practice drills have been implemented and closed out

❒ Regular Quantitative Risk Assessment (QRA) reviews are undertaken and documented

LEVEL 3

❒ A ‘Zero major incident’ target and policy is in place and has been documented

❒ Communications with the local community show that the risks of major incidents and the associated emergency
response procedures, where applicable, have been discussed
Appendix 3: GSCP Reference Environmental Audit Checks

❒ The local community is involved in site emergency response drills and has been contacted by the site emergency
response team

❒ The employment site has implemented leading practice mechanisms to reduce the potential for major incidents
Environmental Audit Process & Methodology Reference Tools - november 2010

(e.g. process changes etc.)

Global Social Compliance Programme_40

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report

9. Contaminated land/soil and groundwater pollution prevention

Employment site requirements at each performance level:
Level 1:
1. Meet legal requirements
2. Relevant, up-to-date permits are held and compliance maintained
3. Understanding and awareness of site setting/sensitive receptors in site’s vicinity
4. Not causing or knowingly permitting contamination of soil and groundwater
Level 2:
5. Formal systems and processes in place to manage contaminated soil and groundwater as per the site EMS
6. Qualitative, desk-based (as appropriate) soil and groundwater risk assessment completed including:
a. All potential current and historical on-site sources of potential soil and groundwater impact
b. All potential current and historical off-site sources of potential soil and groundwater impact
c. Mapping of all receptors and pathways

41_Global Social Compliance Programme

d. Assessment of risk of soil and groundwater impact
7. All actions completed following results for soil and groundwater risk assessment, e.g. and as required:
a. Focused Phase II investigation
b. Appropriate and efficient remediation of soil and/or groundwater contamination performed
8. Any soil and groundwater contamination is communicated to relevant stakeholders, as required
Level 3:
9. Zero contamination’ target and policy in place
10. Proactive management of soil and groundwater quality
11. Leading practice techniques in place to prevent further/future soil and/or groundwater contamination and in relation to remediation
12. Proactive engagement with stakeholders in the local community to ensure awareness of potential soil and/or groundwater contamination
13. Engagement with appropriate stakeholders down the value chain in relation to the prevention and management of soil and groundwater contamination

The following checks are intended as guidance and should not limit audit activities.

Is this performance area applicable to the employment site? Yes No

If yes, please complete the following table. If no, please proceed to the next Performance Area.
Appendix 3: GSCP Reference Environmental Audit Checks
Environmental Audit Process & Methodology Reference Tools - november 2010
 Evidence Gathering on Contaminated Land/Soil and Groundwater Pollution Prevention notes

9.1 Physical employment site inspection

LEVEL 1

❒ Confirm, through observation, whether substances used, wastes stored and/or activities undertaken at site have
the potential to impact underlying soil and groundwater

❒B
 ulk containers (including tanks), pipework containing substances with the potential to cause impact to the environment
are in good condition and of sound integrity

❒ Secondary containment/bunds are in good condition and are of sound integrity

❒ Procedures established to prevent/reduce the potential for impact to soil and groundwater are being followed
(e.g. management of substances, activities etc.)

❒ Emergency response equipment is available and has been checked to ensure that it is in appropriate working order

❒ No spills or leaks to the environment are observed

❒ There is no staining of unprotected ground

Appendix 3: GSCP Reference Environmental Audit Checks

❒ No areas of the employment site have been subject to burning or burying of waste activities
Environmental Audit Process & Methodology Reference Tools - november 2010

❒ Review neighbouring properties/operations and confirm whether there is the potential for off-site activities impacting
soil and groundwater migrating onto the employment site (this would be an observation rather than a compliance
finding)

9.2 Employment site procedures and processes

LEVEL 1

❒ Policies and procedures in relation to contaminated land/soil and groundwater pollution prevention have been
established and implemented (e.g. written policies and procedures, employee handbook, induction training, etc.)

❒ Formal systems and processes are in place in relation to contaminated land/soil and groundwater pollution prevention
as per the site EMS

Global Social Compliance Programme_42

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
…
9.3 Interviews

Interviews with management confirm the following:

LEVEL 1

❒ Management understands and are aware of site setting/sensitive receptors in site’s vicinity

❒ Management understand the potential impact on soil and groundwater from site activities and operations

❒ Management do not knowingly permit contamination of soil and groundwater

❒ Management is aware of laws and regulations concerning contaminated land/soil and groundwater pollution
prevention and compliance

43_Global Social Compliance Programme

❒ Policies and processes regarding contaminated land/soil and groundwater pollution prevention are effectively
communicated to workers

❒ Management provide the appropriate resources to ensure that compliance with applicable laws and regulations
is maintained

❒ Management confirms that waste materials are not buried on-site currently

❒ Management confirms that waste materials have not been buried on-site historically

LEVEL 2

❒ Management confirms soil and groundwater assessments, and actions resulting from the risk assessment, are completed

❒ Management confirms that the soil and groundwater assessments completed to date take into account all potential
sources of risk to soil and groundwater, namely
• on-site and off-site current and historical sources of contamination;
• the potential soil and groundwater impacts presented by those sources of contamination;
• all pathways and receptors for the contamination identified; and hence
• an overall assessment of risk to soil and groundwater quality

❒ Management confirm that all actions have been completed following results for soil and groundwater risk assessment
including, as required:
• focussed Phase II investigation and
• appropriate and efficient remediation of soil and/or groundwater contamination
Appendix 3: GSCP Reference Environmental Audit Checks
Environmental Audit Process & Methodology Reference Tools - november 2010

…
 …
❒ The employment site ensures any soil and groundwater contamination is communicated to relevant internal
and external stakeholders

LEVEL 3

❒ Management have implemented and promote a ‘Zero contamination’ target and policy

❒ Management are proactive in maintaining and improving soil and groundwater quality

❒ Management actively promotes the implementation of leading practice techniques to prevent further/future soil
and/or groundwater contamination and in relation to remediation

❒ Management are proactive in engaging with stakeholders in the local community to ensure awareness of potential
soil and/or groundwater contamination

❒ Management engage with appropriate stakeholders down the value chain in relation to the prevention
and management of soil and groundwater contamination

Interviews with key workers/other workers used to corroborate worker testimony with Document checks
and management interviews. They confirm the following:

LEVEL 1
Appendix 3: GSCP Reference Environmental Audit Checks

❒ Workers understand how they, and their site’s activities and operations, can impact soil and groundwater
Environmental Audit Process & Methodology Reference Tools - november 2010

❒ Key workers are aware of contaminated land/soil and groundwater pollution prevention permit/licence requirements,
where applicable

❒ Workers receive training on soil and groundwater issues at induction, where appropriate

❒ Key workers with contaminated land/soil and groundwater pollution prevention management responsibilities receive
specific training as required

❒ Workers have access to, and understand, contaminated land/soil and groundwater pollution prevention procedures,
where appropriate

❒ Workers confirm that waste materials are not buried on-site currently

❒ Workers confirm that waste materials have not been buried on-site historically

Global Social Compliance Programme_44

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
…
9.4 Document checks

LEVEL 1

❒ Relevant employment site permits and licences that relate to contaminated land/soil and groundwater pollution
prevention are available and up to date

❒ A ‘Zero contamination’ target and policy is maintained on-site and is available

❒ Where the employment site is legally required to hold and/or maintain documentation in relation to contaminated
land/soil and groundwater pollution prevention, the documentation is retained on file for the required period of time

❒ The employment site has documented the site setting/sensitive receptors in the site’s vicinity

❒ Records of inspections of secondary containment/bunds are available

45_Global Social Compliance Programme

❒ Records of spills or releases to the environment are documented

❒ Any known soil and groundwater impacts arising from off-site sources have been documented

❒ Procedures that address soil and groundwater impacts at the site are made available to relevant employment site
personnel

❒ Training materials (e.g. induction records, training matrix etc.) indicate:

• workers receive training on soil and groundwater issues and pollution prevention; and
• key workers receive training applicable to their contaminated land/soil and groundwater pollution prevention
management roles and responsibilities

LEVEL 2

❒ The employment site maintains documentation relating to soil and groundwater risk assessments including, where
appropriate, focussed Phase II investigations, monitoring results and remediation activities

LEVEL 3

❒ The employment site has implemented leading practice techniques to prevent further/future soil and/or groundwater
contamination and in relation to remediation

❒ Communications with appropriate stakeholders and the local community through the value chain show that
the prevention and management of soil and groundwater contamination have been discussed
Appendix 3: GSCP Reference Environmental Audit Checks
Environmental Audit Process & Methodology Reference Tools - november 2010
 10. Land use and biodiversity
Employment site requirements at each performance level:
Level 1:
1. Meet legal requirements relating to planning and development
2. Relevant, up-to-date permits are held and compliance maintained
3. No negative impact on designated protection areas or species
Level 2:
4. Formal systems and processes in place to manage land use and biodiversity as per the site EMS
5. In agricultural production, proactive management to maintain soil fertility, avoid soil erosion and promote soil and biodiversity recovery
6. Where appropriate, demonstrable improvement in land use and biodiversity performance including deforestation, rehabilitation and conservation activities
Level 3:
7. Land use is sustainable within local ecosystem context
8. Leadership role in biodiversity conservation, for example partnership with relevant local organisations
9. Leading practice mechanisms in place to promote biodiversity and leading practice land management
10. Engagement with appropriate stakeholders down the value chain to improve land use and biodiversity performance, within and beyond site boundaries
11. Demonstrable achievement of stretching targets beyond recognised international standard practice
Appendix 3: GSCP Reference Environmental Audit Checks

The following checks are intended as guidance and should not limit audit activities.
Environmental Audit Process & Methodology Reference Tools - november 2010

Is this performance area applicable to the employment site? Yes No

If yes, please complete the following table. If no, please proceed to the next Performance Area.

Global Social Compliance Programme_46

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
…
Evidence Gathering on Land Use and Biodiversity notes

10.1 Physical employment site inspection

LEVEL 1

❒ Employment site operations and activities observed are in line with legal requirements relating to land use (including
planning permission and development requirements)

❒ Review current development or construction activities to ensure that negative impacts to land use or biodiversity
are minimised

❒ Review a number of operational activities to check whether site land use and biodiversity procedures are being
implemented

10.2 Employment site procedures and processes

47_Global Social Compliance Programme

LEVEL 1

❒ Policies and procedures in relation to land use management have been established and implemented
(e.g. written policies and procedures, employee handbook, induction training etc.)

❒ Policies and procedures in relation to biodiversity management have been established and implemented
(e.g. written policies and procedures, employee handbook, induction training etc.)

LEVEL 2

❒ Formal systems and processes are in place in relation to land use management as per the site EMS

❒ Formal systems and processes are in place in relation to biodiversity management as per the site EMS

10.3 Interviews

Interviews with management confirm the following:

LEVEL 1

❒ Management is aware of the land uses to which the site can be used

❒ Management understand the potential impact on biodiversity from site activities and operations
Appendix 3: GSCP Reference Environmental Audit Checks

❒ Management is aware of laws and regulations concerning land use and biodiversity and compliance
Environmental Audit Process & Methodology Reference Tools - november 2010

…
 …
❒ Policies and processes regarding land use and biodiversity are effectively communicated to workers

❒ Management provide the appropriate resources to ensure that compliance with applicable laws and regulations
is maintained

LEVEL 2

❒ In agriculture production management actively promotes or endorses proactive management in agricultural
production to maintain soil fertility, avoid soil erosion and promote soil and biodiversity recovery

❒ The employment site demonstrates, where appropriate, improvement in land use and biodiversity performance
including deforestation, rehabilitation and conservation activities

LEVEL 3

❒ Management understands the concept of sustainable land use within the local ecosystem context

❒ The employment site demonstrates a leadership role in biodiversity conservation (e.g. by partnering with local
organisations)

❒ Management actively promotes the implementation of leading practice mechanisms in relation to biodiversity
and land management
Appendix 3: GSCP Reference Environmental Audit Checks

❒ Management understands what recognised international standard practice is in relation to land use and biodiversity
for their sector/geography and have set targets that exceed those practices
Environmental Audit Process & Methodology Reference Tools - november 2010

Interviews with key workers/other workers used to corroborate worker testimony with Document checks
and management interviews. They confirm the following:

LEVEL 1

❒ Workers understand how they, and their site’s activities and operations, can impact land use and biodiversity

❒ Key workers are aware of land use and biodiversity permit/licence requirements (including planning permission
requirements), where applicable

❒ Workers receive training on land use and biodiversity issues at induction, where appropriate

❒ Key workers with land use and biodiversity management responsibilities receive specific training as required

❒ Workers have access to, and understand, land use and biodiversity procedures, where appropriate

Global Social Compliance Programme_48

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
…
10.4 Document checks

LEVEL 1

❒ Relevant employment site permits and licences that relate to land use and biodiversity (including planning
permission/consent and development requirements) are available and up to date

❒ Where the employment site is legally required to hold and/or maintain documentation in relation to land use
and biodiversity, the documentation is retained on file for the required period of time

❒ Procedures that address land use and biodiversity issues at the site (including planning of new developments,
construction, changing processes etc.) are made available to relevant employment site personnel

❒ If there have been recent changes on site (e.g. building extensions, process changes, new buildings etc.), check
to ensure that potential impacts on land use and biodiversity have been considered and documented

49_Global Social Compliance Programme

❒ Training materials (e.g. induction records, training matrix etc.) indicate:
• workers receive training on land use and biodiversity issues; and
• key workers receive training applicable to their land use and biodiversity management roles and responsibilities

❒ There is documented evidence that demonstrates that the employment site does not negatively impact designated
protection areas or species

LEVEL 2

❒ The employment site has made demonstrable improvement in land use and biodiversity performance

LEVEL 3

❒ Communications with local organisations show that the employment site is taking a leading role in biodiversity
conservation

❒ The employment site has identified whether land use is sustainable (in relation to the local ecosystem context)

❒ The employment site has implemented leading practice mechanisms to promote biodiversity and land management

❒ Land use and biodiversity performance targets are stretching and are being achieved

❒ Communications with appropriate stakeholders through the value chain show that land and biodiversity performance
have been discussed
Appendix 3: GSCP Reference Environmental Audit Checks
Environmental Audit Process & Methodology Reference Tools - november 2010
 11. Nuisance
Employment site requirements at each performance level:
Level 1:
1. Meet legal requirements
2. Relevant, up-to-date permits are held and compliance maintained
3. Understanding and awareness of nuisance levels from site activities and associated impacts (including odour, noise, visual and general housekeeping)
Level 2:
4. Formal systems and processes in place to manage nuisances (including odour, noise, visual and general housekeeping) and complaints as per the site EMS
5. Impacts and complaints data are made available to relevant internal and external stakeholders
6. Impacts and complaints reduction targets are reviewed on an annual basis to drive continuous improvement
7. Demonstrable reduction in nuisance impacts and complaints
Level 3:
8. ‘ Zero complaints’ target and policy in place
9. Proactive engagement with local community/stakeholders to reduce impacts
10. Leading practice mechanisms in place to ensure reduction of impacts e.g. process changes
11. Demonstrable achievement of stretching performance targets beyond recognised international standard practice
Appendix 3: GSCP Reference Environmental Audit Checks

The following checks are intended as guidance and should not limit audit activities.
Environmental Audit Process & Methodology Reference Tools - november 2010

Is this performance area applicable to the employment site? Yes No

If yes, please complete the following table. If no, please proceed to the next Performance Area.

Global Social Compliance Programme_50

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
…
Evidence Gathering on Nuisance notes

11.1 Physical employment site inspection

LEVEL 1

❒ Confirm, through observation, whether activities undertaken at site, and resulting normal emissions) have
the potential to cause nuisance to surrounding neighbours

❒ There are no emissions to air, water or land that have the potential to cause nuisance

❒ Confirm, through observation, whether there are any sensitive off-site receptors adjacent to the employment site
(e.g. schools, housing, etc.)

❒ Emissions from the employment site are not noted at the site perimeter

❒ Procedures established to prevent/reduce the potential for impacts to surrounding areas are being followed

51_Global Social Compliance Programme

(e.g. management of waste, activities etc.)

❒ Emergency response equipment is available and has been checked to ensure that it is in appropriate working order

❒ General housekeeping across the employment site is of an acceptable standard

❒ No spills or leaks to the environment are observed

11.2 Employment site procedures and processes

LEVEL 1

❒ Policies and procedures in relation to nuisance management have been established and implemented (e.g. written
policies and procedures, employee handbook, induction training, etc.)

❒ Formal systems and processes are in place to manage nuisances (including odour, noise, visual and general
housekeeping) as per the site EMS

❒ Formal systems and processes are in place to manage complaints arising from on-site nuisances as per the site EMS

11.3 Interviews

Interviews with management confirm the following:

LEVEL 1

❒ Management understand and are aware of potential nuisance levels from site activities and associated impacts
Appendix 3: GSCP Reference Environmental Audit Checks

(including odour, noise, visual and general housekeeping)

Environmental Audit Process & Methodology Reference Tools - november 2010

…
 …
❒ Management is aware of laws and regulations concerning nuisance and compliance

❒ Policies and processes regarding nuisance are effectively communicated to workers

❒ Management is aware of complaints that are received by the employment site

❒ Management provide the appropriate resources to ensure that compliance with applicable laws and regulations
is maintained

LEVEL 2

❒ Management are proactively driving continuous improvement through reviewing complaints targets on an annual basis

❒ The employment site ensures impacts and complaints data is made available to relevant internal and external
stakeholders and local communities

❒ The employment site demonstrates, where appropriate, improvement in nuisance impacts and complaints

LEVEL 3

❒ Management have implemented and promote a ‘Zero complaints’ target and policy

❒ Management actively promotes the implementation of leading practice mechanisms in relation to reducing impacts
(e.g. through process changes)
Appendix 3: GSCP Reference Environmental Audit Checks

❒ Management understands what recognised international standard practice is in relation to nuisance management
for their sector/geography and have set targets that exceed those practices
Environmental Audit Process & Methodology Reference Tools - november 2010

Interviews with key workers/other workers used to corroborate worker testimony with Document checks
and management interviews. They confirm the following:

LEVEL 1

❒ Workers understand how they, and their site’s activities and operations, can impact surrounding neighbours

❒ Key workers are aware of nuisance permit/licence requirements, where applicable

❒ Workers receive training on nuisance issues at induction, where appropriate

❒ Key workers with nuisance and complaints management responsibilities receive specific training as required

❒ Workers have access to, and understand, nuisance procedures, where appropriate

Global Social Compliance Programme_52

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
…
11.4 Document checks

LEVEL 1

❒ Relevant employment site permits and licences that relate to nuisance are available and up to date

❒ The employment site maintains an up to date complaints register

❒ A ‘Zero complaints’ target and policy is maintained on-site and is available

❒ Where the employment site is legally required to hold and/or maintain documentation in relation to nuisance
and complaints, the documentation is retained on file for the required period of time

❒ Procedures that address nuisance impacts at the site are made available to relevant employment site personnel

53_Global Social Compliance Programme

❒ Training materials (e.g. induction records, training matrix etc.) indicate:
• workers receive training on nuisance issues; and
• key workers receive training applicable to their nuisance and complaints management roles and responsibilities

LEVEL 2

❒ The employment site has made demonstrable improvement in nuisance impacts and complaints performance

LEVEL 3

❒ The employment site has implemented leading practice mechanisms to promote nuisance impact management

❒ Nuisance impacts and complaints performance targets are stretching and are being achieved

❒ Communications with appropriate stakeholders and the local community through the value chain show that nuisance
impacts and complaints issues have been discussed
Appendix 3: GSCP Reference Environmental Audit Checks
Environmental Audit Process & Methodology Reference Tools - november 2010
 GSCP Reference Environmental Audit Report
GSCP Reference Environmental Self Assessment Questionnaire

introduction
Appendix 4

Risk Assessment System

GSCP Reference
Environmental

GSCP Reference Environmental Supplementary Audit Information

Alert Notification

Audit Request
GSCP Reference Environmental Pre-Audit Employment Site Profile
Where a ‘critical’ non-compliance

Preparation
is identified:
Where a ‘critical’ non-compliance is identified, the auditor Please note that if an auditor believes they might be at risk

Audit Execution
should follow the escalation policies of the audit requestor. as a result of communicating a critical non-compliance,

GSCP Reference Environmental Summary of Findings and Corrective Actions

Wherever possible, the auditor should inform the audit the audit team should wait until it is removed from that
requestor as soon as a ‘critical’ non-compliance is identified. situation before issuing the alert notification.
If the audit requestor is on site, the auditor should
Auditors should prioritise the welfare of workers when
communicate the critical non-compliance immediately. This
deciding how to inform employment site management of any
will enable the audit requestor and the employment site to
critical non-compliance. Auditors should follow the escalation

GSCP Reference Environmental Audit Checks

work together to plan an appropriate and timely resolution
policies of the audit requestor to minimise any risk to workers.

Audit Outputs
to the issue.

Examples of critical non-compliances include

• An environmental aspect which represents imminent risk • Auditors denied access or obstructed from conducted from

Glossary
of serious or significant impact to the environment (e.g. conducting a proper audit
major damage to a local ecosystem, closure of a potable
• Non-operation of critical abatement equipment e.g. air
water abstraction point, known on-site or off-site impact
emission scrubber, incineration unit etc.
to soil, groundwater or surface water).
• Evidence of the deliberate provision of false information
GSCP Reference Environmental Alert Notification

• Relevant inventory/register not established in relation to

Appendices

to auditors or regulators so as to disguise non-compliances

a particular Performance Area, which has the potential
with permit/licence/consent requirements.
to result in non-compliance with permit/licence/consent
requirements or which results in mis-management of • Performance or monitoring data manipulated or
environmental matters with the potential for significant misreported to intentionally mislead regulators.
impact to the environment.
• A major non-compliance from a previous audit that has
• Site currently under threat of prosecution, fine and/or not been addressed or in relation to which no significant
enforcement in relation to an environmental issue, e.g. the improvement has been made by the time of a follow up
site has identified that permit/licence/consent/exemption is audit and which has increased the level of environmental
required, but not obtained it. risk, e.g. of causing incidents.
• An attempt to pervert the course of the audit through • Site knowingly utilises illegal/unlicensed external third
fraud, coercion, deception or interference. parties in relation to environmental matters (e.g. waste
removal/disposal).
• A systemic violation of a legal requirement that has attracted
(or could likely attract) regulator intervention (e.g. continued
illegal disposal of waste materials, either on-site or off-site).

Global Social Compliance Programme_01

 GSCP Reference Environmental Audit Report
GSCP Reference Environmental Self Assessment Questionnaire
introduction

Appendix 4: GSCP Reference Environmental Alert Notification

Environmental Audit Process & Methodology Reference Tools - november 2010
Risk Assessment System

Reference Alert Notification

GSCP Reference Environmental Supplementary Audit Information

1. Key information
Employment site and Audit Information
Audit Request

GSCP Reference Environmental Pre-Audit Employment Site Profile

Name of the audited company:

Supplier name:

Employment site name:

Preparation

Country:

Audit date:

Date of alert:
Audit Execution

GSCP Reference Environmental Summary of Findings and Corrective Actions

Lead auditor:

Issue area(s):

GSCP Reference Environmental Audit Checks
Audit Outputs

2. Details of critical non-compliance(s)

Critical non-compliances should be presented in a consistent format, with sufficient detail concerning the issue(s) and its
context to enable useful remediation discussions to begin. A table should be completed for each issue found.

Critical Non-compliance
Glossary

Legislation or environmental topic:

Description of critical non-compliance:

GSCP Reference Environmental Alert Notification
Appendices

Auditor findings (description,

extent of issue, direct consequences
of the issue, etc):

Documentary, interview and other

evidence found:

Management response:

Proposed corrective actions:

02_Global Social Compliance Programme

 GSCP Reference Environmental Self Assessment Questionnaire

introduction
GSCP Reference Environmental Audit Report

Risk Assessment System

Appendix 5
GSCP Reference

GSCP Reference Environmental Supplementary Audit Information

Environmental Audit Report

Audit Request
GSCP Reference Environmental Pre-Audit Employment Site Profile
This tool forms part of the GSCP set of reference tools for a site in the supply chain to demonstrate continuous
designed to provide a common interpretation of local and improvement in its environmental performance from basic

Preparation
international environmental standards and requirements and compliance to leading-edge performance (across three
environmental reference codes (if available and applicable). defined ‘levels’ for eleven different performance areas).
The Environmental Reference Requirements reflect a
common understanding of good environmental practice and The reference tools on Environmental Audit Process and
are applicable to all raw material processing, agricultural, Methodology are based on the GSCP Environmental
manufacturing and logistics sites in the supply chain. The Reference Requirements but can be adopted and tailored to

Audit Execution
Environmental Reference Requirements provide a model other codes of environmental practice.

GSCP Reference Environmental Summary of Findings and Corrective Actions

The context, findings, issues and actions

GSCP Reference Environmental Audit Checks

against each area of the audit standard

Audit Outputs
used should be reported to the audit
requestor
Glossary
The report should include: For each environmental Performance Area, the report should:
• a summary of the auditors’ evaluation of the employment •d
 escribe the current situation including which of the GSCP
GSCP Reference Environmental Alert Notification

site’s performance against each of the 11 Performance Environmental Reference Requirements the site is currently
Appendices

Areas; meeting;
• identified non-compliances which indicate that the • provide evidence and information to substantiate the findings;
employment site is not meeting Level 1 of the GSCP
• for each non-compliance or observation, provide a:
Environmental Reference Requirements;
/ description of the non-compliance or observation and
• observations and good practices.
its frequency;
/ evidence found to substantiate it;
/ classification to applicable law, code of conduct, etc;
/ if required by the audit requestor, recommended
corrective action with a timeframe for completion and
responsibility.

Global Social Compliance Programme_01

 GSCP Reference Environmental Self Assessment Questionnaire
introduction

GSCP Reference Environmental Audit Report

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010
Risk Assessment System

The report should include photos of the employment site Auditors may feel the need to separately report to the audit
such as*: requestor in the event that, for example, the auditor has:
• outside general overview; • information that is too sensitive for the audit report itself;
• inside general overview • concerns which cannot be substantiated through evidence
and/or interviews;
• key activities and processes that have potential environmental
impact; • commentary/insight on the attitude of management
GSCP Reference Environmental Supplementary Audit Information

towards the non-compliances or where management was

• waste handling and storage areas;
Audit Request

obstructive to the audit process;

GSCP Reference Environmental Pre-Audit Employment Site Profile

• hazardous substance storage areas;

• concerns about the possibility of falsified records.
• areas of potential impact to soil and groundwater including
The process for reporting such information should be agreed
staining and distressed vegetation;
between the audit requestor and the auditor in advance of
• bulk storage tanks and secondary containment; the audit.
• wastewater treatment areas; This type of reporting may not be appropriate where the
Preparation

audit requestor is the employment site itself.

• abatement equipment;
• good practices where these can be photographed;
• non-compliances where these can be photographed.
Unless agreed by all parties in writing, the audit organisation
Audit Execution

will not distribute the report to any entities except the audit
requestor. However, the audit requestor should share the
report with the employment site/customer/supplier as soon
GSCP Reference Environmental Summary of Findings and Corrective Actions

as possible in order to facilitate co-operation on continuous

improvement.
GSCP Reference Environmental Audit Checks
Audit Outputs
Glossary

GSCP Reference Environmental Alert Notification

Appendices

*Photographs should only be taken with the permission of the employment site as they may contain or reveal confidential information.

02_Global Social Compliance Programme

 1. Executive Summary
This Audit Report summarises the key findings from an audit undertaken at the <<site>> against applicable legal requirements and the GSCP Environmental Reference
Requirements. Further information on the GSCP Environmental Reference Requirements can be found in the main body of this report.
The audit was undertaken by <<auditor(s) name(s)>> on <<date>>, on behalf of <<audit requestor>>.
<<Please include a brief summary of overall environmental performance identified during the site visit, highlighting key strengths and also areas for improvement>>.
The following table records the key findings from the audit against the three performance levels for each of the 11 Environmental Performance Areas outlined in the
GSCP Environmental Reference Requirements.

GSCP Environmental Reference Number of non-compliances

Requirements Level rating Please indicate if zero
(Not achieved Level 1, (Please indicate in brackets the number Number of
Environmental Performance Area Level 1, Level 2, Level 3) of legal compliances identified) Observations
Auditor level rating Critical Major Minor

Example Performance Area Not achieved Level 1 1 (0) 5 (2) 5 (4) 3

Environmental management systems

Appendix 5: GSCP Reference Environmental Audit Report

Energy use, transport GHGs

Water use
Environmental Audit Process & Methodology Reference Tools - november 2010

Wastewater/effluent

Emissions to air

Waste management

Pollution prevention/hazardous and potentially hazardous

substances

Major incident management

Contaminated land/soil and groundwater pollution prevention

Land use and biodiversity

Nuisance

Global Social Compliance Programme_03

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 GSCP Reference Environmental Self Assessment Questionnaire
introduction

GSCP Reference Environmental Audit Report

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010
Risk Assessment System

2. Reference Audit Report

2.1 General information
GSCP Reference Environmental Supplementary Audit Information

1.0 Employment site contact Name:

details:
Audit Request

Address:
GSCP Reference Environmental Pre-Audit Employment Site Profile

Country:

Telephone:

Fax/email:
Preparation

GPS cordinates:

Is this site in an Export Processing Zone (EPZ)*? Yes ❒ No ❒

1.1 Audit date(s):

Audit Execution

1.2 Report issue date:

1.3 Audit type: Initial Full Audit Announced

Follow-up Partial Audit Semi-announced
GSCP Reference Environmental Summary of Findings and Corrective Actions

Unannounced

1.4 Audit conducted by: Auditing Company (please provide name below)
GSCP Reference Environmental Audit Checks
Audit Outputs

Retailer
Brand Owner
Purchaser
NGO
Union
Multiple parties. If yes, please list.
Glossary

1.5 Audit personnel Name: Name:

(please specify the names Title: Title:
and titles of the auditors
and worker interviewers Name: Name:
GSCP Reference Environmental Alert Notification

who conducted the audit) Title: Title:

Appendices

1.6 Time in and time out: In: Out:

1.7 Previous audit details (if any): • Audited conducted by:

• Audit date:

• Audit type:

* “Industrial zones with special incentives set up to attract foreign investors, in which imported materials undergo some degree of processing before being re-exported”
(ILO, 2007)

04_Global Social Compliance Programme

 GSCP Reference Environmental Self Assessment Questionnaire

introduction
GSCP Reference Environmental Audit Report
Appendix 5: GSCP Reference Environmental Audit Report
Environmental Audit Process & Methodology Reference Tools - november 2010

Risk Assessment System

…
• Audited conducted by:

GSCP Reference Environmental Supplementary Audit Information

• Audit date:

Audit Request
GSCP Reference Environmental Pre-Audit Employment Site Profile
• Audit type:

• Audited conducted by:

Preparation
• Audit date:

• Audit type:

1.8 Supplier name:

Audit Execution
1.9 Main employment site contact: Name:

Position:

GSCP Reference Environmental Summary of Findings and Corrective Actions

Telephone:

1.10 Name and job title of Name:

GSCP Reference Environmental Audit Checks

employment site representative Title:

Audit Outputs
who signed the summary of
findings and corrective actions

1.11 Audits results reviewed by Yes No

employment site management?

1.12 Audit report author:

1.13 Audit report reviewer:

Glossary
1.14 General remarks: GSCP Reference Environmental Alert Notification

Appendices

Global Social Compliance Programme_05

 GSCP Reference Environmental Self Assessment Questionnaire
introduction

GSCP Reference Environmental Audit Report

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010
Risk Assessment System

2.2 Employment site information

2.2.1 Production systems and processes

2.1.1 Industry sector:

GSCP Reference Environmental Supplementary Audit Information

2.1.2 Principal products:

Audit Request

GSCP Reference Environmental Pre-Audit Employment Site Profile

2.1.3 Main export markets:

2.1.4 Main production processes

(e.g. Stitching, labelling,
injection, moulding, baking,
harvesting, dyeing etc.):
Preparation

2.1.5 Main production equipment:

2.1.6 Main raw materials used:

2.1.7 List of hazardous chemicals

Audit Execution

used employment site:

GSCP Reference Environmental Summary of Findings and Corrective Actions

2.2.2 Audit overview and history

GSCP Reference Environmental Audit Checks

2.2.1 Applicable environment-related code of conduct, if appropriate

Audit Outputs

2.2.2 Was a perimeter survey undertaken? Yes No

If Yes, please detail the results
Glossary

2.2.3 Were any alert notifications issued as part of this audit? Yes No
If yes, how many?
GSCP Reference Environmental Alert Notification
Appendices

06_Global Social Compliance Programme

 GSCP Reference Environmental Self Assessment Questionnaire

introduction
GSCP Reference Environmental Audit Report
Appendix 5: GSCP Reference Environmental Audit Report
Environmental Audit Process & Methodology Reference Tools - november 2010

Risk Assessment System

2.3 Reporting template
The audit report includes ‘Findings’ and ‘Evidence’ columns as per the example below for each of the 11 Performance Areas
against which the audit was conducted. For follow-up audits, the report issued should be an updated version of the original
report, with all new issues and updates to previous issues clearly highlighted. An example of how to include follow-up
information in the audit report template is shown below.

GSCP Reference Environmental Supplementary Audit Information

Audit Request
GSCP Reference Environmental Pre-Audit Employment Site Profile
Finding Evidence
(Summary of requirement, plus description of the finding, (A description of the evidence observed and related to the
details of the management position, any management audit check guidelines. Please indicate the type of evidence
involvement and element of the law that has been violated) listed e.g. worker interview, documentary, observational)

e.g. Waste Management Documentary

Site was not in possession of appropriate waste permit. No permit available.

Preparation
Management Interview
Site management not aware of requirement.

Follow up 01/06/09 – Follow-up 01/06/09 –

Site obtained relevant permit from local authority. Documentary
Copy of permit sent to auditor.

Audit Execution
Follow up 01/06/09 – New Issue Follow up 01/06/09 – New issue
Waste management Management Interviews
Site management has not communicated requirements of Management reported that it has scheduled a half day

GSCP Reference Environmental Summary of Findings and Corrective Actions

permit to relevant site personnel. awareness raising session on requirements of the new waste
permit.

GSCP Reference Environmental Audit Checks

Audit Outputs
The tables below present the findings of the audit against The Audit Report records whether the non-compliance
each of the GSCP Environmental Reference Requirement. At identified is a non-compliance with specific legal requirements.
Level 1 non-compliances are categorised into Critical, Major
and Minor non-compliances, together with an indication Minor
as to where these represent non-compliances with legal

Glossary
• basic environmental management structure and defined
requirements. in case legal requirements do not exist in the
management responsibilities are in place, however, this is
site’s country of operations, these reference requirements
not documented;
can be used as reference and also as parameters against
which non compliances can be identified. • site has identified and is managing its potentially significant
GSCP Reference Environmental Alert Notification

aspects and impacts but has not documented this process/

Appendices

For Level 2 and Level 3, the tables state whether a particular

the results;
requirement has been ‘met’ or ‘not met’. There is then
a summary of good practices identified. Each section is • relevant inventory/register established in relation to a
completed with an overall summary statement in relation to particular Performance Area, but not actively maintained;
which Level the auditor believes the site has achieved.
• an occasional or isolated compliance issue e.g. missing
records/documentation in relation to permit/consent/
Definitions and examples of non-compliances: licence requirements;
• the site has a mechanism to remain up to date with applicable
A non-compliance is a specific breach of the standard or
local legal requirements, but has not documented this
code against which the employment site was audited.
process;
In relation to Level 1 Requirements, a non-compliance is
• an issue which presents a risk to the environment (low risk)
categorised as a:
(either on-site or the surrounding areas);
• minor non-compliance;
• site has a procedure to ensure that external third parties
• major non-compliance; or utilised by the site for environmental matters (e.g. waste
• critical non-compliance. removal/disposal) are appropriately licensed, but has not
documented this process;

Global Social Compliance Programme_07

 GSCP Reference Environmental Self Assessment Questionnaire
introduction

GSCP Reference Environmental Audit Report

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010
Risk Assessment System

• occasional or isolated instances of missing monitoring/ • site currently under threat of prosecution, fine and/or
performance data (that is not a legal requirement). enforcement in relation to an environmental issue;
• an attempt to pervert the course of the audit through
Major
fraud, coercion, deception or interference;
• basic management structure/defined management
• a systemic violation of a legal requirement that has attracted
responsibilities not in place, either in relation to overall
(or could likely attract) regu lator intervention (e.g. continued
environmental management or particular Performance
GSCP Reference Environmental Supplementary Audit Information

illegal disposal of waste materials, either on-site or off-site);

Area;
Audit Request

• auditors denied access or obstructed from conducted from

GSCP Reference Environmental Pre-Audit Employment Site Profile

• site has identified that it has potentially significant

conducting a proper audit;
environmental aspects/impacts, but has not acted on this
information; • non-operation of critical abatement equipment e.g. air
emission scrubber, incineration unit, etc;
• site is not aware of its legal requirements in relation to a
particular performance area; • evidence of the deliberate provision of false information
to auditors or regulators so as to disguise non-compliances
• site has no mechanism for remaining up to date with
Preparation

with permit/licence/consent requirements;

applicable legal requirements;
• performance or monitoring data manipulated or
• site not aware of relevant permit/licence/consent/exemption
misreported to intentionally mislead regulators;
requirements;
• a major non-compliance from a previous audit that has not
• breaches of legislation or permit/licence/consent
been addressed or for which no significant improvement
requirements which represents risk of moderate harm to
Audit Execution

has been made by the time of a follow up audit, and

the environment e.g. exceedance of wastewater discharge
which has increased the level of environmental risk, e.g. of
limits, exceedance of air emission limit concentration, etc;
causing incidents;
• a systemic breach or violation of a legal requirement;
• site knowingly utilises illegal/unlicensed external third
GSCP Reference Environmental Summary of Findings and Corrective Actions

• a breach of a legal requirement or environmental permit/ parties in relation to environmental matters (e.g. waste
licence/consent which is considered likely to attract removal/disposal).
GSCP Reference Environmental Audit Checks

regulator intervention;
Critical non-compliances should trigger an alert notification
Audit Outputs

• site has not confirmed that all external third parties utilised [see Section 4.5].
by the site for environmental matters (e.g. waste removal/
• An Observation
disposal) are appropriately licensed;
/ a possible issue which could develop into a non-
• relevant inventory/register not established in relation to a compliance if action is not taken by the Employment
particular Performance Area; Site (i.e. a potential non-compliance).
• consumption/generation data not collected in relation to / an issue, on which the auditor has some evidence to
Glossary

a particular Performance Area that is relevant to the site; indicate that it may be present, but is not confirmed by
more than one data point.
• site has not provided identified and/or provided training
to employees on environmental matters which represent a / an opportunity for improvement e.g. how the
serious or significant impact to the environment. employment site can meet the requirements of the
GSCP Reference Environmental Alert Notification

next performance level.

Appendices

Critical • Good Practice

• an environmental aspect which represents imminent risk / an innovative or novel approach to managing
of serious or significant impact to the environment (e.g. environmental issues in relation to a particular
major damage to a local ecosystem, closure of a potable Performance Area.
water abstraction point, known on-site or off-site impact
to soil, groundwater or surface water); Level 2 and Level 3 findings
• site has identified that a permit/licence/consent/exemption is The GSCP Environmental Reference Requirements at levels
required, but has not obtained it; 2 and 3 are intended to drive performance improvement. As
such, the auditor should record only whether the Employment
• relevant inventory/register not established in relation to
Site has met or not met a particular Requirement, as well
a particular Performance Area, which has the potential
as observations and examples of good practice. Where the
to result in non-compliance with permit/licence/consent
auditor identifies that a Requirement is not met, they should
requirements or which results in mis-management of
provide a short description as to why.
environmental matters with the potential for significant
impact to the environment;

08_Global Social Compliance Programme

 3. Reference Audit Report by performance areas
1.0 Environmental Management Systems

Report

LEVEL 1

Non-Compliance Type
Please tick one column and also note Evidence
if it is a legal issue? Finding (A description of the evidence observed
Observation? Summary of requirement, plus description and related to the audit check guidelines.
Legal of the finding and element of the law Please indicate the type of evidence
Critical Major Minor that has been violated) listed e.g. worker interview,
Issue?
documentary, observational)
❒ ❒ ❒ ❒ ❒
Appendix 5: GSCP Reference Environmental Audit Report
Environmental Audit Process & Methodology Reference Tools - november 2010

Global Social Compliance Programme_09

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
…
LEVEL 2

Evidence
Not
Requirement Met Observation? (A description of the evidence observed
Met
and related to the audit check guidelines)

Environmental Management System (EMS) is established, documented,

implemented, maintained and continually reviewed/improved
The EMS includes:
• environmental Policy;
• planning: environmental risk assessment, setting objectives
❒ ❒
and targets;
• implementation and operation: operational procedures;
adequate training; documentation and its control;
• checking: monitoring and measurement, audit and inspections;
• management Review.

10_Global Social Compliance Programme

Information on environmental performance is made available
to appropriate internal and external stakeholders ❒ ❒
(please refer to the guidance section for detailed definition)

LEVEL 3

Forward looking environmental strategy to drive leading practice ❒ ❒

Environmental management and environmental performance targets

are designed to improve or sustain the environment and local ecosystem, ❒ ❒
or global when appropriate

Proactive engagement with relevant stakeholders to achieve significant

❒ ❒
performance improvement

Where relevant, commitment to voluntary standards ❒ ❒

…
Appendix 5: GSCP Reference Environmental Audit Report
Environmental Audit Process & Methodology Reference Tools - november 2010
introduction Risk Assessment System Audit Request Preparation Audit Execution Audit Outputs Glossary Appendices
GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Audit Checks GSCP Reference Environmental Alert Notification
GSCP Reference Environmental Audit Report GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Summary of Findings and Corrective Actions

Global Social Compliance Programme_11

Environmental Audit Process & Methodology Reference Tools - november 2010
Appendix 5: GSCP Reference Environmental Audit Report

on page 5.
Note to auditor: If this report relates to a follow-up audit, then please copy the tables from above and replicate here with the findings presented as per the template
❒ Level 3 ❒ Level 2 ❒ Level 1 ❒ Level 1 not achieved Summary: overall level achieved for environmental management systems:
(please provide a short description of the good practice measure identified)
Examples of good practice identified
…
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report

2.0 Energy Use, Transport and Greenhouse Gases (GHGs)

Report

LEVEL 1

Non-Compliance Type
Please tick one column and also note Evidence
if it is a legal issue? Finding (A description of the evidence observed
Observation? Summary of requirement, plus description and related to the audit check guidelines.
Legal of the finding and element of the law Please indicate the type of evidence
Critical Major Minor that has been violated) listed e.g. worker interview,
Issue?
documentary, observational)
❒ ❒ ❒ ❒ ❒

12_Global Social Compliance Programme

LEVEL 2

Evidence
Not
Requirement Met Observation? (A description of the evidence observed
Met
and related to the audit check guidelines)

Formal systems and processes in place to manage and audit energy

❒ ❒
use and GHG emissions as per the site EMS

Energy consumption and greenhouse gas emissions (including

on-site vehicle emissions) are made available to appropriate internal ❒ ❒
and external stakeholders

Renewable energy use targets and GHG emission reduction targets

(normalised) are established/reviewed at least on an annual basis ❒ ❒
to drive continuous improvement

Demonstrable reduction in energy (normalised; please refer

❒ ❒
to the guidance section for further definition)

Targets include on-site vehicle emissions reduction, which are reviewed

❒ ❒
Appendix 5: GSCP Reference Environmental Audit Report

on an annual basis to drive continuous improvement

Environmental Audit Process & Methodology Reference Tools - november 2010

…
 …
LEVEL 3

Leading practice mechanisms in place to reduce greenhouse gas (GHG)

❒ ❒
intensity (for further definition please refer to the guidance section)

Use of energy sources with lower GHG intensity ❒ ❒

• Energy consumption level is sustainable within availability

❒ ❒
of local energy resources

• Demonstrable achievement of stretching energy and fuel efficiency

and GHG emission targets beyond recognised international standard ❒ ❒
practice

Engagement with appropriate stakeholders down the value chain

❒ ❒
identifying ways to reduce GHG emissions

Carbon accounting in business system ❒ ❒

Specification of the most environmentally efficient combinations

❒ ❒
of vehicle types, fuels and technologies for distribution fleet
Appendix 5: GSCP Reference Environmental Audit Report

Fuel consumption and vehicle emission reduction targets are reviewed

❒ ❒
on an annual basis to drive continuous improvement for the entire fleet
Environmental Audit Process & Methodology Reference Tools - november 2010

Examples of good practice identified

(please provide a short description of the good practice measure identified)

Summary: overall level achieved for energy use, transport and Greenhouse Gases (GHG): ❒ Level 1 not achieved ❒ Level 1 ❒ Level 2 ❒ Level 3

Global Social Compliance Programme_13

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report

3.0 Water Use

Report

LEVEL 1

Non-Compliance Type
Please tick one column and also note Evidence
if it is a legal issue? Finding (A description of the evidence observed
Observation? Summary of requirement, plus description and related to the audit check guidelines.
Legal of the finding and element of the law Please indicate the type of evidence
Critical Major Minor that has been violated) listed e.g. worker interview,
Issue?
documentary, observational)
❒ ❒ ❒ ❒ ❒

14_Global Social Compliance Programme

LEVEL 2

Evidence
Not
Requirement Met Observation? (A description of the evidence observed
Met
and related to the audit check guidelines)

Formal systems and processes in place to manage and audit water

❒ ❒
consumption as per the site EMS

Water consumption data are made available to relevant internal

❒ ❒
and external stakeholders

Water consumption efficiency targets are reviewed on an annual basis

❒ ❒
to drive continuous improvement

Demonstrable achievement of water efficiency targets (normalised) ❒ ❒

…
Appendix 5: GSCP Reference Environmental Audit Report
Environmental Audit Process & Methodology Reference Tools - november 2010
 …
LEVEL 3

Where relevant, water consumption level is sustainable within local

❒ ❒
ecosystem limits and water catchment area

Investigation of and use, if relevant, of alternative water sources

❒ ❒
with lower ecosystem impact

Demonstrable achievement of stretching water efficiency targets beyond

❒ ❒
recognised international standard practice

Leading practice water efficiency mechanisms in place, including re-use,

❒ ❒
recovery and recycling

Engagement with appropriate stakeholders down the value chain

❒ ❒
to improve water efficiency

Examples of good practice identified

(please provide a short description of the good practice measure identified)
Appendix 5: GSCP Reference Environmental Audit Report
Environmental Audit Process & Methodology Reference Tools - november 2010

Summary: overall level achieved for water use: ❒ Level 1 not achieved ❒ Level 1 ❒ Level 2 ❒ Level 3

Global Social Compliance Programme_15

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report

4.0 Wastewater / Effluent

Report

LEVEL 1

Non-Compliance Type
Please tick one column and also note Evidence
if it is a legal issue? Finding (A description of the evidence observed
Observation? Summary of requirement, plus description and related to the audit check guidelines.
Legal of the finding and element of the law Please indicate the type of evidence
Critical Major Minor that has been violated) listed e.g. worker interview,
Issue?
documentary, observational)
❒ ❒ ❒ ❒ ❒

16_Global Social Compliance Programme

LEVEL 2

Evidence
Not
Requirement Met Observation? (A description of the evidence observed
Met
and related to the audit check guidelines)

Formal systems and processes in place to manage wastewater effluent

❒ ❒
as per the site EMS

Basic on-site wastewater treatment in place to achieve improvements in

❒ ❒
wastewater quality or connection to off-site wastewater treatment system

Regular wastewater quality testing/ monitoring is undertaken to ensure

❒ ❒
ongoing compliance with permitted effluent limits and as per the site’s EMS

Wastewater quality data are made available to relevant internal and

❒ ❒
external stakeholders

Wastewater quality and volume improvement targets are reviewed

❒ ❒
on an annual basis to drive continuous improvement

❒ ❒
Appendix 5: GSCP Reference Environmental Audit Report

Demonstrable improvement in wastewater quality

Environmental Audit Process & Methodology Reference Tools - november 2010

…
 …
LEVEL 3

Wastewater effluent quality and discharge volume are sustainable

❒ ❒
in the context of local receptors and ecosystem limits

Leading practice wastewater treatment in place ❒ ❒

Leading practice mechanisms in place to improve quality of wastewater

❒ ❒
discharged to local environment, including reuse of grey water

Demonstrable achievement of stretching wastewater effluent quality

improvement and volume reduction targets (normalised) beyond ❒ ❒
recognised international standard practice

Engagement with appropriate stakeholders down the value chain

❒ ❒
to improve wastewater effluent quality

Examples of good practice identified

(please provide a short description of the good practice measure identified)
Appendix 5: GSCP Reference Environmental Audit Report
Environmental Audit Process & Methodology Reference Tools - november 2010

Summary: overall level achieved for wastewater/effluent: ❒ Level 1 not achieved ❒ Level 1 ❒ Level 2 ❒ Level 3

Global Social Compliance Programme_17

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report

5.0 Emissions to air

5.1 General

Report

LEVEL 1

Non-Compliance Type
Please tick one column and also note Evidence
if it is a legal issue? Finding (A description of the evidence observed
Observation? Summary of requirement, plus description and related to the audit check guidelines.
Legal of the finding and element of the law Please indicate the type of evidence
Critical Major Minor that has been violated) listed e.g. worker interview,
Issue?
documentary, observational)
❒ ❒ ❒ ❒ ❒

18_Global Social Compliance Programme

LEVEL 2

Evidence
Not
Requirement Met Observation? (A description of the evidence observed
Met
and related to the audit check guidelines)

Formal systems and processes in place to manage emissions to air

❒ ❒
as per the site EMS

Regular air emissions quality testing/monitoring is undertaken

❒ ❒
to ensure ongoing compliance with permitted limits

Air emissions quality data are made available to relevant internal

❒ ❒
and external stakeholders

Air quality improvement targets are reviewed on an annual basis

❒ ❒
to drive continuous improvement

Demonstrable reduction in emissions to air (normalised) ❒ ❒

Appendix 5: GSCP Reference Environmental Audit Report

…
Environmental Audit Process & Methodology Reference Tools - november 2010
 …
LEVEL 3

Emissions to air are sustainable within local ecosystem limits ❒ ❒

Leading practice abatement technologies in place to minimise emissions

❒ ❒
to air or efforts to reduce emissions at source

Demonstrable achievement of stretching air quality improvement targets

❒ ❒
beyond recognised international standard practice

Engagement with appropriate stakeholders down the value chain to

❒ ❒
reduce emissions to air

Additional and proactive emissions monitoring performed ❒ ❒

Examples of good practice identified

(please provide a short description of the good practice measure identified)
Appendix 5: GSCP Reference Environmental Audit Report
Environmental Audit Process & Methodology Reference Tools - november 2010

Summary: overall level achieved for emissions to air, general: ❒ Level 1 not achieved ❒ Level 1 ❒ Level 2 ❒ Level 3

Global Social Compliance Programme_19

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report

5.0 Emissions to air

5.2 Ozone Depleting Substances (ODS)

Report

LEVEL 1

Non-Compliance Type
Please tick one column and also note Evidence
if it is a legal issue? Finding (A description of the evidence observed
Observation? Summary of requirement, plus description and related to the audit check guidelines.
Legal of the finding and element of the law Please indicate the type of evidence
Critical Major Minor that has been violated) listed e.g. worker interview,
Issue?
documentary, observational)
❒ ❒ ❒ ❒ ❒

20_Global Social Compliance Programme

LEVEL 2

Evidence
Not
Requirement Met Observation? (A description of the evidence observed
Met
and related to the audit check guidelines)

Proactive ODS leak detection and maintenance of ODS-containing

❒ ❒
equipment

Targets in place to phase-out use of specific types of ODS, such as CFCs,

❒ ❒
halons, TCE, CCl4 in line with recognised international standard practice

Demonstrable reduction, control and substitution of ODS ❒ ❒

…
Appendix 5: GSCP Reference Environmental Audit Report
Environmental Audit Process & Methodology Reference Tools - november 2010
introduction Risk Assessment System Audit Request Preparation Audit Execution Audit Outputs Glossary Appendices
GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Audit Checks GSCP Reference Environmental Alert Notification
GSCP Reference Environmental Audit Report GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Summary of Findings and Corrective Actions

Global Social Compliance Programme_21

Environmental Audit Process & Methodology Reference Tools - november 2010
Appendix 5: GSCP Reference Environmental Audit Report

❒ Level 3 ❒ Level 2 ❒ Level 1 ❒ Level 1 not achieved Summary: overall level achieved for Ozone Depleting Substances (ODS):
(please provide a short description of the good practice measure identified)
Examples of good practice identified
❒ ❒ Complete phase-out of all ODS (beyond legal requirements)
LEVEL 3
…
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report

6.0 Waste management

Report

LEVEL 1

Non-Compliance Type
Please tick one column and also note Evidence
if it is a legal issue? Finding (A description of the evidence observed
Observation? Summary of requirement, plus description and related to the audit check guidelines.
Legal of the finding and element of the law Please indicate the type of evidence
Critical Major Minor that has been violated) listed e.g. worker interview,
Issue?
documentary, observational)
❒ ❒ ❒ ❒ ❒

22_Global Social Compliance Programme

LEVEL 2

Evidence
Not
Requirement Met Observation? (A description of the evidence observed
Met
and related to the audit check guidelines)

Formal systems and processes in place to manage waste generation,

storage, transportation, and disposal as per the site EMS, including ❒ ❒
waste minimisation audit and consideration of waste hierarchy principles

Evaluation of waste management contractors (suitability, disposal/

❒ ❒
treatment methods)

Engagement with suppliers to identify waste avoidance/ reduction/

❒ ❒
recycling/ reuse opportunities

Segregation of waste streams in line with recognised international

❒ ❒
standard practice

Monitoring and measurement of waste generated and recycled, with

❒ ❒
data available to relevant internal and external stakeholders
Appendix 5: GSCP Reference Environmental Audit Report
Environmental Audit Process & Methodology Reference Tools - november 2010

…
 …
Waste reduction and recycling targets are reviewed at least on an annual
❒ ❒
basis to drive continuous improvement.

Demonstrable waste reduction (normalised) ❒ ❒

LEVEL 3

Waste disposal method and volume is sustainable within local operating

❒ ❒
environment and availability of waste treatment and disposal facilities

Leading practices in place to minimise resource/virgin material use

❒ ❒
and achieve waste reduction/recycling/energy from waste

Demonstrable achievement of stretching waste reduction/recycling

❒ ❒
targets beyond recognised international standard practice

Engagement with appropriate stakeholders down the value chain

to identify waste avoidance/reduction/recycling/reuse/energy from ❒ ❒
waste measures
Appendix 5: GSCP Reference Environmental Audit Report

Examples of good practice identified

(please provide a short description of the good practice measure identified)
Environmental Audit Process & Methodology Reference Tools - november 2010

Summary: overall level achieved for waste management: ❒ Level 1 not achieved ❒ Level 1 ❒ Level 2 ❒ Level 3

Global Social Compliance Programme_23

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report

7.0 Pollution Prevention / Hazardous and Potentially Hazardous Substances

Report

LEVEL 1

Non-Compliance Type
Please tick one column and also note Evidence
if it is a legal issue? Finding (A description of the evidence observed
Observation? Summary of requirement, plus description and related to the audit check guidelines.
Legal of the finding and element of the law Please indicate the type of evidence
Critical Major Minor that has been violated) listed e.g. worker interview,
Issue?
documentary, observational)
❒ ❒ ❒ ❒ ❒

24_Global Social Compliance Programme

LEVEL 2

Evidence
Not
Requirement Met Observation? (A description of the evidence observed
Met
and related to the audit check guidelines)

Formal systems and processes in place for pollution prevention

❒ ❒
and to reduce the potential for pollution incidents as per the site EMS

Dedicated site emergency response team in place to deal with pollution

❒ ❒
incidents

Regular practice drills are carried out for pollution incidents ❒ ❒

Targets are reviewed on an annual basis to reduce the use of hazardous

substances, minimise associated risks and substitute with non-hazardous ❒ ❒
alternatives where possible

Where relevant, specific pollution prevention mechanisms are considered

❒ ❒
in agricultural production, including optimisation of agrichemicals input
Appendix 5: GSCP Reference Environmental Audit Report
Environmental Audit Process & Methodology Reference Tools - november 2010

…
 …
Demonstrable reduction in hazardous substances use (normalised)
❒ ❒
and minimisation of associated risks, as appropriate

LEVEL 3

‘Zero pollution incident’ target and policy in place ❒ ❒

Detailed pollution prevention inspections are conducted ❒ ❒

Promote the use of non-hazardous and non-toxic alternative substances ❒ ❒

Demonstrable achievement of stretching hazardous substance reduction/

❒ ❒
substitution targets beyond recognised international standard practice

Engagement with appropriate stakeholders down the value chain

❒ ❒
to improve hazardous substance use

Examples of good practice identified

(please provide a short description of the good practice measure identified)
Appendix 5: GSCP Reference Environmental Audit Report
Environmental Audit Process & Methodology Reference Tools - november 2010

Summary: overall level achieved for pollution prevention/hazardous and potentially hazardous substances:
❒ Level 1 not achieved ❒ Level 1 ❒ Level 2 ❒ Level 3

Global Social Compliance Programme_25

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report

8.0 Major incident management

Report

LEVEL 1

Non-Compliance Type
Please tick one column and also note Evidence
if it is a legal issue? Finding (A description of the evidence observed
Observation? Summary of requirement, plus description and related to the audit check guidelines.
Legal of the finding and element of the law Please indicate the type of evidence
Critical Major Minor that has been violated) listed e.g. worker interview,
Issue?
documentary, observational)
❒ ❒ ❒ ❒ ❒

26_Global Social Compliance Programme

LEVEL 2

Evidence
Not
Requirement Met Observation? (A description of the evidence observed
Met
and related to the audit check guidelines)

Formal systems and processes in place to manage emergency response

❒ ❒
as per the site EMS

Reduction in potential occurrence and impacts of major incidents

❒ ❒
(e.g. explosions, fires, major spills etc.)

Regular Quantitative Risk Assessment (QRA) reviews ❒ ❒

Major incidents reported to relevant stakeholders ❒ ❒

Dedicated site emergency response team in place ❒ ❒

Regular practice drills are carried out for all emergency scenarios ❒ ❒
Appendix 5: GSCP Reference Environmental Audit Report
Environmental Audit Process & Methodology Reference Tools - november 2010

…
 …
LEVEL 3

Zero major incident’ target and policy in place ❒ ❒

Proactive engagement with local community to ensure awareness

❒ ❒
of risks of major incidents and emergency response procedures

Local community is involved in site’s emergency response drill and has

❒ ❒
been contacted by the emergency response team, as relevant

Leading practice mechanisms in place to reduce risk of major incidents

❒ ❒
e.g. process changes

Examples of good practice identified

(please provide a short description of the good practice measure identified)
Appendix 5: GSCP Reference Environmental Audit Report

Summary: overall level achieved for major incident management: ❒ Level 1 not achieved ❒ Level 1 ❒ Level 2 ❒ Level 3
Environmental Audit Process & Methodology Reference Tools - november 2010

Global Social Compliance Programme_27

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report

9.0 Contaminated land/Soil and Groundwater Pollution Prevention

Report

LEVEL 1

Non-Compliance Type
Please tick one column and also note Evidence
if it is a legal issue? Finding (A description of the evidence observed
Observation? Summary of requirement, plus description and related to the audit check guidelines.
Legal of the finding and element of the law Please indicate the type of evidence
Critical Major Minor that has been violated) listed e.g. worker interview,
Issue?
documentary, observational)
❒ ❒ ❒ ❒ ❒

28_Global Social Compliance Programme

LEVEL 2

Evidence
Not
Requirement Met Observation? (A description of the evidence observed
Met
and related to the audit check guidelines)

Formal systems and processes in place to manage contaminated soil

❒ ❒
and groundwater as per the site EMS

Qualitative, desk-based (as appropriate) soil and groundwater risk

❒ ❒
assessment completed including:

a. All potential current and historical on-site sources of potential soil

❒ ❒
and groundwater impact

b. All potential current and historical off-site sources of potential soil

❒ ❒
and groundwater impact

c. Mapping of all receptors and pathways ❒ ❒

Appendix 5: GSCP Reference Environmental Audit Report

d. Assessment of risk of soil and groundwater impact ❒ ❒

Environmental Audit Process & Methodology Reference Tools - november 2010

…
 …
All actions completed following results for soil and groundwater risk
❒ ❒
assessment, e.g. and as required:

a. Focused Phase II investigation ❒ ❒

b. Appropriate and efficient remediation of soil and/or groundwater

❒ ❒
contamination performed

Any soil and groundwater contamination is communicated to relevant

❒ ❒
stakeholders, as required

LEVEL 3

‘Zero contamination’ target and policy in place ❒ ❒

Proactive management of soil and groundwater quality ❒ ❒

Leading practice techniques in place to prevent further/future soil

❒ ❒
and/or groundwater contamination and in relation to remediation

Proactive engagement with stakeholders in the local community to

Appendix 5: GSCP Reference Environmental Audit Report

❒ ❒
ensure awareness of potential soil and/or groundwater contamination

Engagement with appropriate stakeholders down the value chain in

Environmental Audit Process & Methodology Reference Tools - november 2010

relation to the prevention and management of soil and groundwater ❒ ❒

contamination

Examples of good practice identified

(please provide a short description of the good practice measure identified)

Summary: overall level achieved for contaminated land/soil and groundwater pollution prevention: ❒ Level 1 not achieved ❒ Level 1 ❒ Level 2 ❒ Level 3

Global Social Compliance Programme_29

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report

10.0 Land Use and Biodiversity

Report

LEVEL 1

Non-Compliance Type
Please tick one column and also note Evidence
if it is a legal issue? Finding (A description of the evidence observed
Observation? Summary of requirement, plus description and related to the audit check guidelines.
Legal of the finding and element of the law Please indicate the type of evidence
Critical Major Minor that has been violated) listed e.g. worker interview,
Issue?
documentary, observational)
❒ ❒ ❒ ❒ ❒

30_Global Social Compliance Programme

LEVEL 2

Evidence
Not
Requirement Met Observation? (A description of the evidence observed
Met
and related to the audit check guidelines)

Formal systems and processes in place to manage land use and

❒ ❒
biodiversity as per the site EMS

In agricultural production, proactive management to maintain soil

❒ ❒
fertility, avoid soil erosion and promote soil and biodiversity recovery

Where appropriate, demonstrable improvement in land use and

biodiversity performance including deforestation, rehabilitation ❒ ❒
and conservation activities

…
Appendix 5: GSCP Reference Environmental Audit Report
Environmental Audit Process & Methodology Reference Tools - november 2010
 …
LEVEL 3

Land use is sustainable within local ecosystem context ❒ ❒

Leadership role in biodiversity conservation, for example partnership

❒ ❒
with relevant local organisations

Leading practice mechanisms in place to promote biodiversity

❒ ❒
and leading practice land management

Engagement with appropriate stakeholders down the value chain

to improve land use and biodiversity performance, within and beyond ❒ ❒
site boundaries

Demonstrable achievement of stretching targets beyond recognised

❒ ❒
international standard practice

Examples of good practice identified

(please provide a short description of the good practice measure identified)
Appendix 5: GSCP Reference Environmental Audit Report
Environmental Audit Process & Methodology Reference Tools - november 2010

Summary: overall level achieved for land use and biodiversity: ❒ Level 1 not achieved ❒ Level 1 ❒ Level 2 ❒ Level 3

Global Social Compliance Programme_31

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report

11.0 Nuisances

Report

LEVEL 1

Non-Compliance Type
Please tick one column and also note Evidence
if it is a legal issue? Finding (A description of the evidence observed
Observation? Summary of requirement, plus description and related to the audit check guidelines.
Legal of the finding and element of the law Please indicate the type of evidence
Critical Major Minor that has been violated) listed e.g. worker interview,
Issue?
documentary, observational)
❒ ❒ ❒ ❒ ❒

32_Global Social Compliance Programme

LEVEL 2

Evidence
Not
Requirement Met Observation? (A description of the evidence observed
Met
and related to the audit check guidelines)

Formal systems and processes in place to manage nuisances (including

odour, noise, visual and general housekeeping) and complaints as per ❒ ❒
the site EMS

Impacts and complaints data are made available to relevant internal

❒ ❒
and external stakeholders

Impacts and complaints reduction targets are reviewed on an annual

❒ ❒
basis to drive continuous improvement

Demonstrable reduction in nuisance impacts and complaints ❒ ❒

…
Appendix 5: GSCP Reference Environmental Audit Report
Environmental Audit Process & Methodology Reference Tools - november 2010
 …
LEVEL 3

Zero complaints’ target and policy in place ❒ ❒

Proactive engagement with local community/ stakeholders to reduce

❒ ❒
impacts

Leading practice mechanisms in place to ensure reduction of impacts

❒ ❒
e.g. process changes

Demonstrable achievement of stretching performance targets beyond

❒ ❒
recognised international standard practice

Examples of good practice identified

(please provide a short description of the good practice measure identified)
Appendix 5: GSCP Reference Environmental Audit Report

Summary: overall level achieved for nuisances: ❒ Level 1 not achieved ❒ Level 1 ❒ Level 2 ❒ Level 3
Environmental Audit Process & Methodology Reference Tools - november 2010

Global Social Compliance Programme_33

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 GSCP Reference Environmental Self Assessment Questionnaire
introduction

GSCP Reference Environmental Audit Report

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010
Risk Assessment System

4. On-Site Pictures
Auditors should include relevant photos that were taken as part of the audit in this section of the audit report. Relevant photos
may include general pictures of the employment site – such as pictures of the employment site or pictures of the production
floor, or they may be specific to the details of the audit report – such as a picture of a non-compliance, observation or best
GSCP Reference Environmental Supplementary Audit Information

practice.
Audit Request

The suggested photos below are examples, and the auditor should include all relevant photos.
GSCP Reference Environmental Pre-Audit Employment Site Profile

Photo Photo Photo

Preparation

Outside view of employment site buildings Employment site entrance Processes

Audit Execution

GSCP Reference Environmental Summary of Findings and Corrective Actions

Photo Photo Photo

GSCP Reference Environmental Audit Checks
Audit Outputs

Waste skips Chemical storage cupboard Above ground storage tank

Glossary

Photo Photo Photo

GSCP Reference Environmental Alert Notification
Appendices

Non-compliance 1 Observation 1 Best Practice 1

Photo Photo Photo

34_Global Social Compliance Programme

 GSCP Reference Environmental Audit Report
GSCP Reference Environmental Self Assessment Questionnaire

introduction
Appendix 6
GSCP Reference

Risk Assessment System

Environmental
Supplementary

GSCP Reference Environmental Supplementary Audit Information

Audit Information

Audit Request
GSCP Reference Environmental Pre-Audit Employment Site Profile
This tool forms part of the GSCP set of reference tools continuous improvement in its environmental performance
designed to provide a common interpretation of local and from basic compliance to leading-edge performance (across

Preparation
international environmental standards and requirements three defined ‘levels’ for eleven different performance
and environmental reference codes (if available and areas).
applicable). The Environmental Reference Requirements
reflect a common understanding of good environmental
practice and are applicable to all raw material processing, The reference tools on Environmental Audit Process and
agricultural, manufacturing and logistics sites in the supply Methodology are based on the GSCP Environmental

Audit Execution
chain. The Environmental Reference Requirements provide Reference Requirements but can be adopted and tailored to
a model for a site in the supply chain to demonstrate other codes of environmental practice.

GSCP Reference Environmental Summary of Findings and Corrective Actions

GSCP Reference Environmental Audit Checks
Supplementary Audit Report

Audit Outputs
Auditors may feel the need to produce a separate, Supplementary reports may be appropriate:
supplementary report for the audit requestor containing:
• if workers appear to be under undue pressure from
• information too sensitive for the audit report; management on the day of audit;

Glossary
• concerns which cannot be substantiated through evidence • if management was obstructive or reluctant to accept
and/or interviews; findings and the need for remediation;
• attitude of management towards the non-compliances or • where the auditor has concerns about the possibility of
GSCP Reference Environmental Alert Notification

the audit process as a whole. falsified records;

Appendices

• where sensitive issues could not be discussed during the

closing meeting because of a potential risk to workers’
wellbeing.

Global Social Compliance Programme_01

 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report

Area of Concern

and its potential consequences)

02_Global Social Compliance Programme

(Description of the issue, who was involved or effected
observed)
(a description of the evidence
Evidence / Observations
Reference environmental supplementary audit information

Related

requirement
Environmental
Standard or legal
Appendix 6: GSCP Reference Environmental Supplementary Audit Information
Environmental Audit Process & Methodology Reference Tools - november 2010
 GSCP Reference Environmental Audit Report
GSCP Reference Environmental Self Assessment Questionnaire

introduction
Appendix 7
GSCP Reference

Risk Assessment System

Summary of
Environmental Findings

GSCP Reference Environmental Supplementary Audit Information

and Corrective Actions

Audit Request
GSCP Reference Environmental Pre-Audit Employment Site Profile
This tool forms part of the GSCP set of reference tools The reference tools on Environmental Audit Process and

Preparation
designed to provide a common interpretation of local and Methodology are based on the GSCP Environmental
international environmental standards and requirements and Reference Requirements but can be adopted and tailored to
environmental reference codes (if available and applicable). other codes of environmental practice.
The Environmental Reference Requirements reflect a
The reference Summary of Environmental Findings and
common understanding of good environmental practice and
Corrective Actions has been designed to provide a structure
are applicable to all raw material processing, agricultural,
to the audit team’s findings and help the audit team develop
manufacturing and logistics sites in the supply chain. The

Audit Execution
a corrective action plan and structure a closing meeting.
Environmental Reference Requirements provide a model

GSCP Reference Environmental Summary of Findings and Corrective Actions

for a site in the supply chain to demonstrate continuous
improvement in its environmental performance from basic
compliance to leading-edge performance (across three
defined ‘levels’ for eleven different performance areas).

GSCP Reference Environmental Audit Checks

Audit Outputs
A note on Corrective Actions
Audit requestors (companies and/or individuals) may take a However, reference is made here to both ‘findings

Glossary
number of different approaches with respect to corrective and corrective actions’ on the understanding that the
actions, for example: identification of corrective actions may be required.
• require auditors solely to identify corrective actions and The Summary of Findings and Corrective Actions template
require the employment site to develop the corrective includes:
GSCP Reference Environmental Alert Notification

action plan following the audit; or

Appendices

• audit findings: Summary of non compliances, good

• require auditors to identify evidence-based findings and practice, and evidence found;
work with the employment site to develop a corrective
• classification of non compliances;
action plan; or
• reference to the applicable code of conduct and/or law
• require auditors to identify evidence-based findings,
which has been contravened;
develop the appropriate corrective action and agree with
the employment site on their follow-up. • recommended corrective actions: Auditors suggestion on
how the audit findings can be resolved;
• person/party responsible for corrective action;

Global Social Compliance Programme_01

 GSCP Reference Environmental Audit Report
GSCP Reference Environmental Self Assessment Questionnaire
introduction

Appendix 7: GSCP Reference Environmental Summary of Findings and Corrective Actions

Environmental Audit Process & Methodology Reference Tools - november 2010
Risk Assessment System

• verification method: The Summary of Findings and Corrective Actions should:

/ a desk-based follow up may be used to verify corrective • be clearly described and written in both English and the
actions for minor non-compliances but provide language spoken by the employment site management;
less assurance than a follow-up audit. Desk-based
GSCP Reference Environmental Supplementary Audit Information

• be distributed as follows:

verification should check corrective actions through
photos, copies of certificates, invoices, etc. submitted / a signed copy for the employment site manager;
by the employment site. Desk-based follow-up cannot / a signed copy retained by the auditor together with
be used where actions need to be verified through other audit documentation;
Audit Request

worker testimony;
GSCP Reference Environmental Pre-Audit Employment Site Profile

/ a hard or soft copy to the audit requestor.

/ f ollow-up audits are recommended for critical or
major non-compliances or when corrective actions can
be evaluated only through interviews and extensive NB: Where employment site representatives are unwilling to
documentation reviews (see section 5.4 of the sign an English language copy of the Summary of Findings
reference audit process); and Corrective Actions, the auditor should still sign their
• timescale for completion: The amount of time required for English language copy and should indicate that they have
Preparation

the issue to be closed. The time allocated for corrective witnessed the representative’s signature on the copy signed
actions to be completed should be appropriate, realistic by management.
and timely.
Audit Execution

GSCP Reference Environmental Summary of Findings and Corrective Actions

GSCP Reference Environmental Audit Checks
Audit Outputs
Glossary

GSCP Reference Environmental Alert Notification

Appendices

02_Global Social Compliance Programme

introduction Risk Assessment System Audit Request Preparation Audit Execution Audit Outputs Glossary Appendices
GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Audit Checks GSCP Reference Environmental Alert Notification
GSCP Reference Environmental Audit Report GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Summary of Findings and Corrective Actions

Global Social Compliance Programme_03

Reference Summary of Environmental
Appendix 7: GSCP Reference Environmental Summary of Findings and Corrective Actions

Findings and Corrective Actions

Auditor name and organisation:

Audit requestor:
Environmental Audit Process & Methodology Reference Tools - november 2010

Audit date:

Time out:
Time in:
1. Employment site and auditor details

Employment site representative (name and position):

Employment site address:
Employment site name:
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report

2. Details of non-compliances and corrective actions

The audit findings are based upon on-site observation, interviews with employees and management, and document review:

Classification Performance
of non- area (in GSCP
Audit Findings Suggested corrective Person / party Verification Timescale for
compliance Environmental
(non compliance) actions responsible method completion
(Critical, Major, Reference
Minor) Requirements)

04_Global Social Compliance Programme

Appendix 7: GSCP Reference Environmental Summary of Findings and Corrective Actions
Environmental Audit Process & Methodology Reference Tools - november 2010
introduction Risk Assessment System Audit Request Preparation Audit Execution Audit Outputs Glossary Appendices
GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Audit Checks GSCP Reference Environmental Alert Notification
GSCP Reference Environmental Audit Report GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Summary of Findings and Corrective Actions

Global Social Compliance Programme_05

Appendix 7: GSCP Reference Environmental Summary of Findings and Corrective Actions
Environmental Audit Process & Methodology Reference Tools - november 2010

Requirements)
(where required) required) (where required) Reference
actions (where applicable)
completion method (where responsible Environmental Audit findings (observation)
Suggested corrective
Timescale for Verification Person / party area (in GSCP
Performance
3. Details of observations
 Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction

GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire
GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report

4. Employment site comments or dispute of findings

Where an agreement cannot be reached between employment site management and auditors regarding findings and/or corrective actions, employment sites can
outline the disagreements in the box below:

Employment site representative

Comments Date
signature

06_Global Social Compliance Programme

Appendix 7: GSCP Reference Environmental Summary of Findings and Corrective Actions
Environmental Audit Process & Methodology Reference Tools - november 2010
 5. Acceptance of findings and corrective actions
A closing meeting has been undertaken and the above findings and corrective actions were discussed and agreed:

Employment site representative name Signature - employment

Signature – auditor Date Date
and position site representative

Does the employment site Representative above have the authority to complete all actions listed? Yes No
If No, who would have the necessary authority to take decisions on these points?
(Please provide names, positions and contact details of additional managers):
Environmental Audit Process & Methodology Reference Tools - november 2010
Appendix 7: GSCP Reference Environmental Summary of Findings and Corrective Actions

Global Social Compliance Programme_07

GSCP Reference Environmental Summary of Findings and Corrective Actions GSCP Reference Environmental Supplementary Audit Information GSCP Reference Environmental Audit Report
GSCP Reference Environmental Alert Notification GSCP Reference Environmental Audit Checks GSCP Reference Environmental Pre-Audit Employment Site Profile GSCP Reference Environmental Self Assessment Questionnaire

Appendices Glossary Audit Outputs Audit Execution Preparation Audit Request Risk Assessment System introduction
 The GSCP is facilitated by
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