2021

January

RBA Validated Assessment Program

(VAP)
Operations Manual
Revision 7.0.0 – January 2021
Organizations working with and in the Responsible Business Alliance (RBA)
www.responsiblebusiness.org are working to improve sustainability and social
responsibility within the global supply chain.

These companies recognize a mutual responsibility to ensure working conditions are

safe, workers are treated with respect and dignity, and that manufacturing practices
are environmentally responsible. The Validated Assessment Program (VAP) is a
collaborative approach to auditing to reduce the burden on supply chain companies
from multiple requests for social audits. The VAP meets the need for a high quality,
consistent and cost-effective standard industry assessment for labor, ethics, health,
safety environmental, and management systems practices based on the RBA code of
conduct, laws, and regulations.

For more information about the Validated Assessment Program (VAP), please contact:
• RBA Email: [email protected]
• RBA Address: 1725 Duke Street, Suite 300, Alexandria VA 22314, USA
• RBA Website: www.responsiblebusiness.org
1|
P a g e

© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

Table of Contents
Appendix 10 Code Interpretation Guidance .................................................................... 5
1. General Notes ......................................................................................................................5
2. A. Labor ................................................................................................................................6
A1) Freely Chosen Employment ..................................................................................................... 6
A2) Young Workers........................................................................................................................ 17
A3) Working Hours ........................................................................................................................ 26
A5) Humane Treatment................................................................................................................. 42
A6) Non-Discrimination/Non-Harassment ................................................................................... 46
A7) Freedom of Association ......................................................................................................... 52
3. B. HEALTH & SAFETY .........................................................................................................60
B2) Emergency Preparedness ..................................................................................................... 70
B3) Occupational Injury and Illness ............................................................................................ 82
B4) Industrial Hygiene .................................................................................................................. 90
B5) Physically Demanding Work ................................................................................................. 94
B6) Machine Safeguarding ........................................................................................................... 96
B7) Food, Sanitation and Housing ............................................................................................... 99
B8) Health and Safety Communication ..................................................................................... 106
4. C. ENVIRONMENT ............................................................................................................. 110
C1) Environmental Permits and Reporting ............................................................................... 111
C2) Pollution Prevention and Resource Reduction ................................................................. 115
C3) Hazardous Substances ........................................................................................................ 117
C4) Solid Waste ........................................................................................................................... 122
C5) Air Emissions ........................................................................................................................ 125
C6) Materials Restrictions.......................................................................................................... 130
C7) Water Management .............................................................................................................. 133
C8) Energy Consumption and Greenhouse Gas Emissions ................................................... 137
5. D. ETHICS ......................................................................................................................... 142
D1) Business Integrity ................................................................................................................. 142
D2) No Improper Advantage ...................................................................................................... 145
D3) Disclosure of Information ................................................................................................... 147
D4) Intellectual Property ............................................................................................................ 150
D5) Fair Business, Advertising and Competition .................................................................... 152
D6) Protection of Identity and Non-Retaliation ....................................................................... 154
D7) Responsible Sourcing of Minerals ..................................................................................... 156
D8) Privacy ................................................................................................................................... 160
6. E. MANAGEMENT SYSTEM ............................................................................................... 162
E1) Company Commitment ......................................................................................................... 162
E2) Management Accountability and Responsibility ............................................................... 164
E3) Legal and Customer Requirements ................................................................................... 169
E5) Improvement Objectives ...................................................................................................... 175
E6) Training .................................................................................................................................. 178
E7) Communication ..................................................................................................................... 182
E8) Worker Feedback, Participation and Grievance ............................................................... 186
E9) Audits and Assessments ..................................................................................................... 191
2|
P a g e

© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

 E10) Corrective Action Process ................................................................................................. 194
E11) Documentation and Records .............................................................................................. 197
E12) Supplier Responsibility ....................................................................................................... 200

3|
P a g e

© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

 This page intentionally left blank

4|
P a g e

© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

APPENDIX 10 CODE INTERPRETATION GUIDANCE
1. GENERAL NOTES
This Appendix outlines requirements or AC for site observation, document review, management knowledge and understanding and worker
awareness and understanding for each of the RBA Code provisions as described in the most current VAP OM. These are termed Conformance
Requirements in this Appendix. All of the Conformance Requirements must be met for the Auditors to conclude Conformance for that AC.
The appendix provides also additional clarification, definitions, details and examples. These are termed Additional Assistance. Additional assistance
is guidance and assistance to the Conformance Requirements but do not form in themselves a requirement of conformance.
Additionally, this Appendix provides guidance for rating non-conformance for each of the AC.
The following notes apply for all provisions herein:
• When there is a discrepancy between the RBA code, local law, a participant’s policies or a Collective Bargaining Agreement, the RBA
defines conformance to the RBA code as meeting the strictest requirements (even if it meets RBA code provisions and legal requirements).
A Collective Bargaining Agreement may create requirements beyond the RBA Code requirements. The VA will not validate CBA compliance
where it is stricter than the RBA Code.
• A legal non-conformance is a Major non-conformance unless otherwise stated in a specific provision (e.g. A3.1 if situation of Auditee is
below 60h/w but above local law for ≤40% of the workers) or there is another finding which has a higher non-conformance rating for that
provision.
• For the purpose of rating, an element is defined as any listed Conformance Requirement.
• All communications from Auditee to workers must be done in a language the worker can understand unless otherwise stated in the
provisions. If this is not the case, then the relevant aspect is at minimum a ‘Major’ non-conformance.
• All AC apply to all workers, including temporary, migrant, student and contract, directly and indirectly employed workers that work in the
factory/on production/in warehouse and any other type of worker/employee unless the AC specifically states a narrower focus group.
• Unless otherwise noted, references to percentage of workers in conformance or non-conformance are based upon the defined sample.
• A Process is not required to be in writing as per ISO (unless the AC states specifically it must be documented), however all processes must
be verifiably implemented in a consistent way

• “Supplier” in this section shall mean “Next Tier Major Supplier”. This is different to ‘supplier’ which can be any supplier to the facility.
2. A. LABOR
A1) Freely Chosen Employment
Forced, bonded (including debt bondage) or indentured labor; involuntary or exploitative prison labor; slavery or trafficking of persons
is not permitted. This includes transporting, harboring, recruiting, transferring or receiving persons by means of threat, force, coercion,
abduction or fraud for labor or services. There shall be no unreasonable restrictions on workers’ freedom of movement in the facility
in addition to unreasonable restrictions on entering or exiting company-provided facilities including if applicable, workers’ dormitories
or living quarters. As part of the hiring process, workers must be provided with a written employment agreement in their native
language that contains a description of terms and conditions of employment. Foreign migrant workers must receive the employment
agreement prior to the worker departing from his or her country of origin and there shall be no substitution or change(s) allowed in
the employment agreement upon arrival in the receiving country unless these changes are made to meet local law and provide equal
or better terms. All work must be voluntary, and workers shall be free to leave work at any time or terminate their employment
without penalty if reasonable notice is given as per worker’s contract. Employers and agents may not hold or otherwise destroy or conceal,
confiscate or deny access by employees to employees’ identity or immigration documents, such as government-issued identification,
passports or work permits. Employers can only hold documentation if such holdings are required by law. In this case, at no time should
workers be denied access to their documents. Workers shall not be required to pay employers’, agents’ or sub-agents’ recruitment fees
or other related fees for their employment. If any such fees are found to have been paid by workers, such fees shall be repaid to the
worker.

6 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A1.1 Any type of forced, involuntary or exploitative prison, indentured, bonded (including debt bondage), trafficked or slave labor is not
permitted
Conformance Requirements:

Site Observations Record Review

Not applicable 1) Voluntary work
a) Personnel files and working hour record/wages do not show any form of non-voluntary labor
b) Grievance records do not show any allegation that overtime is not voluntary.
2) Fees
a) All Fees and penalties are disclosed to the workers.
b) Records on Fees are maintained and disclosed to the worker
c) Fees are not permitted under any circumstances.
d) Any Fees are required to be returned to the worker within 90 days of discovery.
3) Loans
a) Personal loans have a repayment maximum of 10 percent of the worker’s monthly gross base wage, (no interest permitted), for no more than 6
monthly installments.
b) Education loan repayments do not exceed 10% of one year of gross base wages. Any education loan cannot be longer than 1 year per loan.

Additional assistance:

Site Observations Record Review

Not applicable 1) Voluntary work
a) examples of non-voluntary work: Lack of workers’ consent to work, unlawful retention of wages or benefits, work through any form of servitude
(e.g. negotiation of visa, housing, work in exchange for training), security guards (armed or unarmed) keep workforce under retention
b) Non-voluntary overtime such as no right for a worker to refuse overtime
2) Fees
a) Payroll, wage and other records reviewed show no prohibited fees, excessive fees, significant debt, and/or significant loans except those
acceptable fees listed in Appendix 13
3) Fees are defined in Appendix 13. If a fee is not specifically listed in Appendix 13 or does not fit any of the example categories, foreign migrant workers
shall not be required to pay anything that a ‘Local worker would not be required to pay.

7 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:

Scenario 1 - Prohibited recruitment and hiring fees that were paid and not reimbursed within 90 days, or as soon as practicable upon discovery.
100-150%*
Frequency \ Severity in monthly gross >5%-100%* >150%*
0-5%* (<1-month gross base salary) (> 1 month – 1.5-month gross base
base wages (<1-month gross base salary) (>1 -1.5-month gross base salary)
salary)
<1% or 3 workers or fewer (whichever is
Minor Minor Major Priority
greater)
>1%-5% or more than 3 workers but less
Major Major Major Priority
than 7 workers

>5%-40% or more than 7 workers Major Major Priority Priority

>40% Major Priority Priority Priority

*total of all fees charged during recruitment and employment

Guidance for auditors: The first column is the addition, and the percentage to evaluate the second column has now changed. Note that “of all fees charged during recruitment and employment” means that
auditors should add the fees, and not consider each one individually for the purposes of the table rating

Scenario 2 - Prohibited recruitment and hiring fees that were paid and reimbursed within 90 days after commencement of employment
Frequency \ Severity in monthly gross >5%-100%* (<1-month gross base salary) >100%* (<1-month gross base salary)
0-5%* (<1-month gross base salary)
base wages
<1% or 3 workers or fewer (whichever is
Minor Minor Major
greater)
>1% or 3 workers or fewer (whichever is
Minor Major Major
greater)
*total of all fees charged during recruitment and employment

Scenario 3 - For findings other than prohibited recruitment and hiring fees paid were not reimbursed within 90 days, or as soon as practicable upon discovery:
Priority Major Minor Not Applicable
One or more of the following is true: One or more of the following is true: Not Applicable Not Applicable
1. Penalty to leave without reasonable notice is >3 1. Termination notice period more than the
months of gross base wages stricter of 1 month or law
2. Workers restricted from voluntary employment 2. Penalty to leave without reasonable notice is
termination or penalized in other ways when >60% of 1 month of gross base wages (about 2-
giving reasonable notice. 3 weeks)
3. A Priority item in A1.3, A1.4 or A1.5 3. Historic non-voluntary labor was present in
4. Non-voluntary labor is present (other than last 12 months (situation was removed, AND
scenarios above or Major nonconformance) system was not updated)
Remote Verification Acceptable: NO

8|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
NOTE: A1 provisions are linked as per the below diagram.

9|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A1.2 Adequate and effective policy and procedures are established ensuring that any form of forced, bonded (including debt bondage),
involuntary or exploitative prison, trafficked or slave labor is not permitted.
Conformance Requirements:
Site Observations Record Review
Not applicable 1) Policies
a) Adequate and effective policies and procedures are in place
i) To ensure that forced, bonded, involuntary or exploitative prison, trafficked or slave labor is NOT permitted
ii) Stating that workers are not required to pay Fees, deposits or incur debt as part of the employment
iii) Stating that when employment has been terminated voluntarily or involuntarily, worker will be paid appropriate amounts for all hours
worked.
b) An implemented procedure to determine the specific amount of any fees and expenses paid by each individual foreign worker prior to
commencement of work.
2) Contracts
a) Labor Agents and Labor Contractors have executed contracts with agreement requirements to ensure conformance with the
policies/procedures.
3) Monitoring
a) Method of monitoring of conformance with policy, monitoring reports and corrective actions are available for review

Additional assistance:

Site Observations Record Review

Not applicable 1) Policies
a) This is applicable for direct and indirect employment workers.
b) Scope of policies and procedures is during recruiting, hiring and employment.
c) Stating that workers are not required to pay either as one-time or installment payments, collected directly or through wage deductions.
2) Any non-conformance that is related to worker employment conditions should still be reported within their appropriate subsection elsewhere (e.g.
if wages are delayed, benefits not paid, then report in A4).

10 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:

Priority Major Minor Not Applicable

Not applicable One or more of the following is true: One or more of the following is true: Not applicable
1. No policy or procedure (must include 1. Policy and procedures are in place for
recruitment and hiring practices, termination recruitment but one of the implementation
and other fees/deposits/debt) components is missing (e.g., monitoring,
2. No monitoring of program effectiveness correction) in either direct workers or those
3. Trafficked or slave labor prohibition employed by Labor Agents and Contractors
requirements are not in contracts with Labor 2. Monitoring of program effectiveness is in place
Agents and Contractors but corrective actions on findings are open/not
4. No contracts are in place between the Auditee in place
and Labor Agents and Contractors
5. Any priority in A1.1

Remote Verification Acceptable: NO

11
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A1.3 Terms of employment are provided in writing and in their native language prior to employment (in case of foreign migrant workers,
before they leave their home country/region and no substitution or change(s) was made in the employment agreement upon arrival in
the receiving country unless these changes are made to meet local law and provide equal or better terms) via employment
letter/agreement/contract and explained verbally in their native language so workers understand what the terms of employment
states.
Conformance Requirements:
Site Observations Record Review
Not applicable 1) All workers
a) Workers are informed prior to employment of the key employment terms and conditions either verbally and in writing via terms of employment
in their native language.
b) Terms of employment state that workers can resign without penalty if reasonable notice is given as per terms of employment
2) Foreign migrant workers:
a) Workers are informed prior to employment and leaving their home country of the key employment terms and conditions either verbally and in
writing via terms of employment in their native language.
b) No substitution or change(s) allowed in the terms of employment upon arrival in the receiving country unless these changes are made to meet
local law and provide equal or better terms
c) Terms of employment comply with ILO conventions on foreign migrant workers
3) Verbal explanation to workers of the key components of the employment conditions in a language they can understand:
a) Nature of work
b) Working hours, Days off and holidays
c) Leave entitlements
d) Benefits (housing, transportation, uniforms, ...)
e) What fees the worker will be charged and the amount(s)
f) Wages and wage deductions (including all components of social insurance) and how these are calculated.
g) Other non-legally required benefits provided (pension, insurances, ...)

Additional assistance:
Site Observations Record Review
Not applicable 1) Penalty = no threat of punishment, fines, violence, or withholding wages)
2) Any terms of employment changes are declared and follow good practice communication/negotiation with worker
3) Defined worker groups (e.g. student, intern, dispatch, etc.) in compliance with legal and/or customer requirements
4) A priority rating on this finding also requires a priority rating for A1.1

12 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
One or more of the following is true: One or more of the following is true: One or more of the following is true: Not applicable
1. Terms of employment substitution for 1. No terms of employment or not in native 1. Terms of employment are provided but are
materially worse conditions (e.g. lower wages, language or not delivered prior to departure (in incomplete (e.g. missing terms or conditions)
different production facility, undisclosed fees case of foreign migrant workers) BUT 2. Defined worker group mix (e.g. student,
for housing, food, etc.) conditions were communicated before work intern, dispatch, etc.) exceeds legal limits by
2. No terms of employment or conditions began (before leaving home in case of migrant >1% but ≤5%.
communicated prior to employment (before worker)
leaving home in case of migrant worker) 2. Terms of employment or conditions
3. Terms of employment contain language to limit communicated were incomplete (missing one
the workers’ ability to voluntarily terminate or more elements)
their employment 3. Defined worker group mix (e.g. student, intern,
dispatch, etc.) exceeds legal limits by >5%
Remote Verification Acceptable: NO

13
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A1.4 Upon hiring, the worker’s government issued identification and personal documentation originals are not held by employer/Labor
Agent or Contractor (if applicable)
Conformance Requirements:
Site Observations Record Review
1) Workers can demonstrate where personal 1) Policy
documents are kept. a) Adequate and effective policies and procedures is in place stating no government issued identification or personal documents originals are held
2) Workers maintain possession or control or stored.
over their identity documents 2) Worker possession
a) Worker files contain no workers' personal documentation originals Employers can only hold documentation if such holdings are required by
law. In this case, at no time should workers be denied access to their documents.

Additional assistance:
Site Observations Record Review
1) Policy/Procedures
a) Auditee may request, where permitted, copies of the original documents).

2) Worker possession
a) Workers' personal documentation originals: e.g. passport; work visa/permit; citizenship, residence, identification, social insurance
cards/documents; birth certificate; bank documents; ...).
b) Employers can only hold documentation if such holdings are required by law. In this case:.
i) Procedures are in place for safe keeping of only those personal documents required by law.
ii) Personal documents must not be tampered with or damaged in any way.
iii) At no time should workers be denied access to their documents.
iv) In no case shall there be a fee for the safe keeping of government-issued identification, passports or work permits.
3) A priority rating on this finding also requires a priority rating for A1.1

Rating:

14 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 Priority Major Minor Not Applicable
1. Any original personal documents are One or more of the following is true: One or more of the following is true: Not Applicable
destroyed, concealed, confiscated, 1. Original personal documents are kept 1. When the law requires holding original
involuntarily held or access is denied when 2. There is no policy for document safekeeping documents, a safe keeping policy and
requested. and/or worker access to their documents when procedures are in place, but workers cannot
the law requires holding original documents access their documents within 12 hours.
3. For workers in any form of
company/agent/contractor provided living 2. For workers in any form of
accommodations, access to personal secure company/agent/contractor provided living
storage is inhibited in >5% of cases. accommodations, access to personal secure
storage is inhibited in ≤5% of cases.
Remote Verification Acceptable: NO

A1.5 There are no unreasonable restrictions on the movement of workers and their access to basic liberties
Conformance Requirements:
Site Observations Record Review
1) Workers move freely when needed to 1) Policy
access basic liberties (no systems for a) Adequate and effective policies and procedures on freedom of movement are in place.
restriction in place such as toilet passes). 2) Records
2) Workers are free to leave the Auditee a) Entry and leave records (if applicable) show no restriction in movement including if applicable, workers’ dormitories or living quarters
location including if applicable, workers’
dormitories or living quarters when not
engaged in work.

Additional assistance:
Site Observations Record Review
1) Freedom to enter and leave site does not 1) Records
apply to prison labor a) Entry and leave records e.g. toilets, drinking water, external medical facilities, factory/dormitory or living quarters exit and entry.

2) If workers reside on site (dormitory or 2) A priority rating on this finding also requires a priority rating for A1.1
living quarters), access to the dormitory or
living quarters is open or there are no
unreasonable restrictions through
procedure or undue security guard
restrictions, on worker’s ability to leave the
facility including during workers' rest time.

Rating:

15
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 Priority Major Minor Not Applicable
One or more of the following is true: One or more of the following is true: One or more of the following is true: Not Applicable
1. Any situation that is putting workers at a health 1. Workers are restricted from movement 1. No policy or procedures are in place on
or safety risk (e.g. locking in factory or through threat or penalty (but not a threat of freedom of movement but there are no
dormitory or living quarters). firing, reporting to authorities or similarly restrictions on freedom of movement.
2. Workers are restricted from movement severe threat), even if a policy is in place. 2. Non-coercive restrictions
through threat of firing, reporting to authorities systems/procedures are used (e.g. toilet
or similarly severe threat. passes)

Remote Verification Acceptable: NO

16
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A2) Young Workers
Child labor is not to be used in any stage of manufacturing. The term “child” refers to any person under the age of 15, or under the age for
completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. Participant shall implement
appropriate mechanism to verify the age of workers. The use of legitimate workplace learning programs, which comply with all laws and
regulations, is supported. Workers under the age of 18 (Young Workers) shall not perform work that is likely to jeopardize their health or
safety of young workers, including night shifts and overtime. Participant shall ensure proper management of student workers through
proper maintenance of student records, rigorous due diligence of educational partners, and protection of students’ rights in accordance
with applicable law and regulations. Participant shall provide appropriate support and training to all student workers. In the absence of
local law, the wage rate for student workers, interns and apprentices shall be at least the same wage rate as other entry-level workers
performing equal or similar tasks. If child labor is identified, assistance/remediation is provided.

17|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A2.1 Workers are not below the minimum age
Conformance Requirements:
Site Observations Record Review
1) No workers on site appear to be under the 1) Records
minimum age. a) Personnel files shows workers are above minimum age or above company policy minimum age (whichever is greater)

Additional assistance:
Site Observations Record Review
1) Records
a) The worker roster shows all workers are above minimum age or above company policy minimum age (whichever is greater)
2) Auditors need to ensure that sample covers all types of workers/employees.

Rating:
Priority Major Minor Not Applicable
1. Confirmed underage workers are present at 1. Two or more of the minimum requirement 1. One of the minimum requirement elements is Not Applicable
the facility or were present at the facility in elements is missing or ineffective missing or ineffective, or a system element is
the last six months not adequately documented or is prohibited

Remote Verification Acceptable: NO

18
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A2.2 An adequate and effective policy and process is established to ensure that workers below the legal minimum working age are not
hired either directly or indirectly via labor agencies/contractors.
Conformance Requirements:
Site Observations Record Review
Not applicable 1) Policy
a) Adequate and effective child labor prohibition policies and procedures are in place
b) There is an adequate process in place to verify the reliability of age documents. Age verification must include visual verification of a government
recognized photographic identification document.
c) There is a reliable ID verification system to control the workers' access into the facility
d) Auditee does not refuse the worker's job application after the “child” worker's age meets legal requirements.
2) Underage assistance
a) There is a procedure to assist underage children found working for the Auditee that is designed to provide for the welfare of the child

Additional assistance:
Site Observations Record Review
1) Policy
a) Inspect and cross-reference to verify the validity at least two types of official ID*
b) Reliable ID verification system to control the workers' access into the facility e.g. finger printing or ID card with owner's photograph to prevent
under-age workers entering the facility by using another person's ID
c) ID types for verification and cross-reference
i) Matching photographic ID to worker’s face
ii) Verification through third-party resources where available, such as Internet resources or local government offices
iii) Birth certificate
iv) Government-issued personal identification card
v) Driver’s license
vi) Voting registration card
vii) “Official stamped” copy of a school certificate
viii) Affidavit from local government representative
ix) Foreign national work permit or other government recognized document.
2) Underage assistance includes
a) Health exam and appropriate action if necessary
b) Completion of compulsory schooling
c) Maintaining the child's income until legally eligible to work
d) When they exist, and are acceptable by law, to move underage workers into proper apprenticeship positions, restricting their hours and type of
work to accommodate educational needs, as required, rather than discharging or fining of these workers.

19 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
1. Child or underage workers are hired directly One or more of the following is true: 1. Formal policy in place, however, the process Not Applicable
or indirectly through a labor agent/contractor 1. No formal policy and process in place AND no is incomplete, or proof-of-age documentation
proof-of-age documentation is missing
2. If A2.1 Priority, then default Major Non-
conformance for inadequate process
Remote Verification Acceptable: NO

20
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A2.3 Workers under the age of 18 are not allowed to perform work that is likely to jeopardize the health or safety of these young
workers, including night work or overtime.
Conformance Requirements:
Site Observations Record Review
1. No workers under 18 are 1) Policy
performing jobs that are a) Adequate and effective young worker policies and procedures are in place
hazardous b) Implementation mechanisms are clearly defined and implemented including:
i) Health checks if required by law
ii) Clear risk evaluation
iii) Restriction on hours worked and time of day worked
iv) Identification and assignment of young workers to non-hazardous positions
v) Young workers are not allowed night work or overtime
2) Records
a) The implementation mechanisms are reflected in personnel files, medical files and work time records.

Additional assistance:
Site Observations Record Review
1) Policy
a) Night work: Night work for Young Workers may be defined specifically by local law though generally means any consecutive period of at least 7 hours between
10 PM and 7 AM
b) Immediate containment, (i.e. re-assignment, putting on to day shift only …not termination) is required in Priority and Major findings regarding young workers
2) Records
a) The analysis 100% of Young Worker working hours, overtime, days of rest are to be noted here in A2.

Rating:

21 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 Priority Major Minor Not Applicable
One or more of the following is true: One or more of the following is true: 1. One of the minimum requirement elements is 1. Policy and implementation
1. Young workers are doing hazardous work 1. No policy missing or ineffective, or a system element is mechanisms are in place AND No
2. Young workers are working overtime 2. Two or more of the minimum requirement not adequately documented or is prohibited workers under age 18 on site.
3. Young workers are doing night work elements is missing or ineffective

Remote Verification Acceptable: NO

22
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A2.4 Adequate and effective Apprentice/Intern/Student Worker employment policies and procedures are in place.

Conformance Requirements:
Site Observations Record Review
1) Student workers/interns/apprentices only perform tasks 1) Policy
related to their field of study or learning of a new vocation a) Adequate and effective policies and procedures on Apprentice/Intern/Student Worker’s assignments:
and shall not perform the tasks prohibited by applicable i) If applicable, a written policy stating that the Auditee does not hire apprentices/interns/student workers.
laws. ii) A commitment to only providing internships/student workers assignments and apprenticeships that complement their
course of study field or learning of a new vocation;
iii) Maximum duration of apprenticeship (not more than 6 months if worker is paid below minimum wage);
iv) No agency or intermediary may be used in connection with the recruitment, hiring, arrangement, and management of student
workers, interns or apprentices;
v) All work is voluntary (including choice of learning placement assignment);
vi) Prohibition of use of student workers, interns or apprentices to simply fill a labor shortage;
2) Records
a) Tri-partite agreement: If applicable, documented specific requirements on tri-party agreement (student workers (and/or legal
guardian), school and Auditee)
b) Personnel records:
c) Maintenance of student worker/intern or apprentices' records in personnel files (includes agreement if applicable, learning
objectives, evaluations, reference to training material, assignment, …);
d) Details on promotion/hiring opportunities after successful apprenticeship, eligibility, recruitment, employment agreement, nature
of work, working hours, wages and benefits
i) Training material: An outline of training program and copies of the training material are available at all times

Additional assistance:
Site Observations Record Review
1) Policy
a) If the student worker/intern or apprentice is a young worker, then all young worker requirements in A2.3 apply (report in A2.3)
b) An apprenticeship is different from worker probation period. Apprentice/ intern/student worker programs are regulated by law
in most countries, with specific limits on:
i) Working hours shall also not conflict with the student worker’s school attendance, duration of training period, and number
of times the same worker can be classified as a trainee;
ii) Auditee shall not deduct educational fees from the student worker’s wages nor shall they deduct placement fees from the
student worker’s wages;
iii) Auditee shall ensure that the student worker is insured against accident or liability and that the student worker is fully
covered for any other forms of insurance required by law or regulation;
iv) The period where wages can be below minimum wage as per law should be limited and reasonable in duration or not longer
than 6 months, whichever is stricter; and

23 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 v) Student workers/interns/apprentices should only be assigned to work activities that complement the academic
degree/certificate or skill enhancement learning goals.
2) Records
a) Tri-partite agreement:
i) Student worker’s full name
ii) Student worker’s emergency contact information
iii) The name and address of the student worker’s school
iv) The name and address of the Auditee, etc.
v) Living conditions (if applicable)
vi) Wages and benefits
vii) Costs (if any) for meals and accommodation (must be no higher than a fair market rate)
viii) Working hours
ix) Nature of work and place where it will be performed
x) Signed in three copies

24 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
1. One or more of the following is true: One or more of the following is true: 1. A policy on learning programs is in
1. Work performed by apprentices is not related 1. No policy on learning programs in place place AND no student workers,
to a field of study or learning of a new vocation. 2. No school due diligence performed interns or apprentices on site
2. Apprenticeship where worker is paid below 3. One of the minimum requirement elements is
minimum wage is longer than 6 months (longer missing or ineffective, or a system element is
than 6 months is only permitted if legal not adequately documented or is prohibited
requirement)
3. No tri-party agreement among the school,
factory and student/parent
4. Intern, student worker or apprentice is hired
through a labor agent/contractor
5. Two or more of the minimum requirement
elements are missing or ineffective
Remote Verification Acceptable: NO

REFERENCE: The table below summarizes specific requirements for student workers, interns, and apprentices:
Requirement Student worker Intern Apprentice

Tri-party agreement (student, school, and company/Auditee) Yes N/A N/A

No financial/scholastic penalty (note scholastic penalty is allowed only if directly

Yes Yes N/A
related to underperformance on educational component of program)

Due Diligence: verify that worker is actively enrolled in a valid program of study at an
educational institution. Take corrective actions to address any non-conformance by an
Yes No N/A
educational institution and establish sanctions as appropriate, including termination of
the relationship

Yes (at least minimum wage during

Wage rate- paid at least the minimum wage
intern period) unless their Yes, unless Law specifically defines a
Yes
performance is significant below lower wage for this type of worker
expectation for that wage cycle
a)
Agreed apprentice wage increase when meeting new skills requirements. Workers after a successful apprenticeship have clearly documented promotion and wage adjustment

25
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 A3) Working Hours
Studies of business practices clearly link worker strain to reduced productivity, increased turnover and increased injury and illness.
Working hours are not to exceed the maximum set by local law. Further, a workweek should not be more than 60 hours per week,
including overtime, except in emergency or unusual situations. All overtime must be voluntary. Workers shall be allowed at least one
day off every seven days.

26|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A3.1 Hours worked in a workweek over the last 12 months does not exceed 60 hours.
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Records:
a) Mandatory sample size of individual time records as well as summary reports, show the number of hours worked - including overtime - per worker
per week should not exceed 60 hours
2) Waivers:
a) If a government waiver/permit or alternative working hour system is in place, then it needs to comply with the RBA Waiver Policy (see Section C: 10
of the VAP Operations Manual).
b) RBA Code requires that companies comply with local law or Code whichever is more stringent. If you have a valid and current government waiver
(e.g. Comprehensive Work Hour System in China which allows shifting of overtime limits) this waiver is considered “local law.” Regardless of the
waiver, the 60 hours/week limit is in place.

Additional assistance:
Site Observations Record Review
Not Applicable 1) Records:
a) Three (3) months will be evaluated from the last 12 months; these months should typically be a peak, a low, and an average month. For each month,
the following is reported:
i) Three (3) month sample
ii) Within sample, by work area
iii) Within sample, by job code
iv) Within sample, by nationality (if foreign migrant workers present)
b) Any workers under the age of 18 must be studied separately.
c) Working hours evaluation sample should be reflect the demographics of location, and not focused on highest hours only
d) Use the official working hour evaluation template
e) If there were multiple work hour recording systems in place during the previous 12 months, the most recent system is to be evaluated. A minimum
of 3 months must be in place and sampled and the sample size should be 3 times the normal sample size.
f) Unless specified otherwise by local legal requirements, this provision does not apply to exempt workers, including those in executive, managerial,
or professional positions.
g) If 60 hours limit are exceeded, ensure this was not because of an Emergency or Unusual Situation. Exceptional circumstances must be documented
at the time of the Emergency or Unusual Situation.
h) Priority audit:
i) For a 90-day Priority audit the trend since last audit must be reviewed. For rating the month immediately preceding the priority audit is used at
3 times normal sample rate.
ii) For a 180-day Priority audit the trend since last audit must be reviewed. For rating the 3 months immediately preceding the priority audit is used
at normal sample rate.

27 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating: If workers under the age of 18 are found to be working in excess of the stricter of law or 60 hours per week is a Priority Non-Conformance.

% of Sample Work Weeks (Total or Specific Area or Function or Nationality)

Work Hours/Week
≤1%** >1% to ≤5% >5% to ≤15% >15% to ≤40% >40%

>84 hours/week Priority

>72 hours/week to ≤84

Conformance Minor Major Priority Priority
hours/week
>60 hours/week to ≤72 Opportunity for
Conformance Minor Major Priority
hours/week Improvement
Opportunity for
>Local law* to ≤60 hours/week Conformance Minor*** Minor*** Major
Improvement
<Local law* AND ≤60
Conformance
hours/week

* Local law is stricter than 60 hours/week

** No tolerance allowed if working hours are >84hours/week
*** Legal non-conformance is rated a major non-conformance except if working hours if below 60h/week but above local law for ≤40%

Remote Verification Acceptable NO

28
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A3.2 Workers receive at least one (1) day off every seven (7) days
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Records:
a) Mandatory sample size of individual work records as well as summary reports (if available) show that the maximum consecutive days worked is equal
to or less than 6 days.

Additional assistance:
Site Observations Record Review
Not Applicable 1) Records:
a) Three (3) months will be evaluated from the last 12 months; these months should typically be a peak, a low, and an average month. For each month, the
following is reported:
i) Three (3) month sample
ii) Within sample, by work area
iii) Within sample, by job code
iv) Within sample, by nationality (if foreign migrant workers present)
b) Any workers under the age of 18 must be studied separately.
c) Working hours evaluation sample should be reflect the demographics of location, and not focused on highest hours only
d) Use the official working hour evaluation template
e) If there were multiple days off recording systems in place during the previous 12 months, the most recent system is to be evaluated. A minimum of 3
months must be in place and sampled and the sample size should be 3 times the normal sample size.
f) Unless specified otherwise by local legal requirements, this provision does not apply to exempt workers, including those in executive, managerial, or
professional positions.
g) If 6 consecutive days are exceeded, ensure this was not because of an Emergency or Unusual Situation. Exceptional circumstances must be documented
at the time of the Emergency or Unusual Situation.
h) Priority audit:
i) For a 90-day Priority audit the trend since last audit must be reviewed. For rating the month immediately preceding the priority audit is used at 3
times normal sample rate.
ii) For a 180-day Priority audit the trend since last audit must be reviewed. For rating the 3 months immediately preceding the priority audit is used at
normal sample rate.

29 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:

If workers under the age of 18 are found to be working consecutive days in excess of the stricter of law or 6 consecutive days is a Priority Non-Conformance unless
required for their qualification/certification under A2.4.

% of Sampled Workers (Total or Specific Area, Function or Nationality)

Consecutive Days >1% to ≤5% of sampled

≤1%** >5% to ≤40% >40%
workers

≥24 Consecutive Days

Priority

>12 to <24 Consecutive Days Minor Minor Major Priority

>6* to ≤12 Consecutive Days Minor Minor Major

Conformance

≤6* Consecutive Days Conformance

*Or legal requirements if stricter than 6 consecutive days

** A tolerance of 1 percent of population is allowed, i.e. if no more than 1 percent of workers is detected to work more than the legal limit then this is conformance,
except if the days off are more than 12 or more days, in which case the 1 percent tolerance does not apply.

Remote Verification Acceptable NO

30 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A3.3 Adequate and effective policy and system/procedures are established to accurately determine, communicate, record, manage and
control working hours including overtime, including reliable and detailed records of workers’ regular and overtime working hours
Conformance Requirements:
Site Observations Record Review
1) Recording devices: 1) Policy:
Time Recording Devices are present, and all are in a) Adequate and effective working hours/days off policies and procedures are in place to
working order. i) Accurately determine
ii) Record
iii) Manage
iv) Control working hours including overtime and days off.
b) If non-conformance is detected, documented corrective action should be implemented and progress against the corrective action
documented.
2) Records:
a) Review the company's time records and system for recording time worked to determine that time is recorded accurately and completely.

Additional assistance:
Site Observations Record Review
1) Policy:
a) The policy and implemented process should at a minimum:
b) Ensure awareness of requirements of compliance with local and national laws and regulations regarding working hours and days off and
RBA requirements
c) Integrate legal and RBA requirements
d) Monitor actual performance
e) Use a strategy to ensure conformance with all requirements.
2) Records:
a) Review the company's time records and system includes:
b) All workers have a time record.
c) Each time record is accurate and can be cross-referenced with leave records, production records, maintenance, procurement or other
relevant records.
d) Regular working time and overtime recording
e) Adequate detail to allow for daily, weekly and monthly working time and overtime analysis.

3) Unintentional errors found in records are covered here. If intentional errors are found, then this is covered in section D3.1

31 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One or more of the following is true: Not Applicable
1. No time recording devices present or time 1. Time records not matching other relevant
recording devices not accurate or not in good Auditee records for >1% to ≤5% of population
working order 2. One of the minimum requirement elements is
2. Time records do not match other relevant missing or ineffective, or a system element is
Auditee records (for greater than 5 percent of not adequately documented or is prohibited
population)
3. Time records are not accurately adjusted after
worker complaint
4. Two or more of the minimum requirement
elements is missing or ineffective
5. If the working hours controls are found to be
in non-conformance (minor, major or priority
finding in A3.1, and / or minor, major or priority
in A3.2), then major finding in A3.3

Remote Verification Acceptable: NO

32
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A3.4 Workers are allowed mandated breaks, holidays and vacation days, including time off when ill or for maternity leave.
Conformance Requirements:
Site Observations Record Review
1) Workers take mandatory breaks which includes at least one meal break per 1) Policy
shift a) Adequate and effective policies and procedures for sick leave, holidays, vacation and paternity/maternity leave
are in place.
b) Workers are provided with mandated meal and rest breaks, leave periods, holidays, and vacation days
2) Records
a) Leave records for 12 months are securely kept, accurate and consistent with medical certificates, actual leaves
and holidays.
b) Payroll records for these absences show that there was no financial penalty for maternity or sick leave.

Additional assistance:
Site Observations Record Review
1) Policy
a) Workers receive a reasonable amount of time off for sickness or maternity without job loss or financial penalty
when supported with a medical certificate.
b) Most countries require workers to be given a 20 or 30-minute break every two or four hours, as well as a defined
meal break. Compare the company's practices to local legal requirements.

Rating:
Priority Major Minor Not Applicable
1. Workers are not allowed time off for illness One or more of the following is true: Holidays and mandatory breaks are provided but: Not Applicable
or maternity with valid medical certificate 1. No policy in place and mandatory 1. No policy is in place
breaks/holidays are not provided or 2. Policy is not communicated to workers
guaranteed.
2. Leave records are not kept or accurate.

Remote Verification Acceptable: NO

33 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A4) Wages and Benefits
Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime
hours and legally mandated benefits. In compliance with local laws, workers shall be compensated for overtime at pay rates greater
than regular hourly rates. Deductions from wages as a disciplinary measure shall not be permitted. The basis on which workers are
being paid is to be provided in a timely manner via pay stub or similar documentation. For each pay period, workers shall be provided
with a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work
performed. All use of temporary, dispatch and outsourced labor will be within the limits of the local law.

34|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A4.1 Wages for regular and overtime hours are correctly calculated, and paid to all workers
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Policy
a) Adequate and effective wages and compensation policies and procedures are in place:
b) “Pay equals time worked” applies; this means any company-required activity
c) All workers shall be paid no less than the agreed* wage for all regular hours.
d) overtime and other compensation and benefits are paid and are on top of agreed* wage for regular hours
e) Payment made to leavers (resigned workers).
2) Records
a) Wages benefits, and overtime are correctly calculated and accurate pay records are maintained for 12 months.
b) Wages are paid directly to workers (or a legally designated third party) with no unauthorized deductions (including for disciplinary measures) in a timely
manner.
c) For recurring pay (including overtime, other) should not be delayed more than two days after the agreed timing for payment
d) For severance pay, payment (including resigned workers) must be made in compliance not later than one month after final day on the job

Additional assistance:
Site Observations Record Review
Not Applicable 1) Policy
a) Company-required activity e.g. briefings, trainings, daily overview meetings, shall be paid equal to the time of this mandatory attended activity.
b) A worker’s base wage shall always be set at or above minimum wage for the classification of worker.
c) This applies to both direct and indirect workers.
d) * Agreed = the stricter of legal minimum wage, wage stipulated in employment contract or wage set in Collective Bargaining Agreement
e) NOTE: In case the country does not have a legal set minimum wage, then the industry prevailing wage will apply as a standard. The industry benchmark and
reference must to be specified under legal references in this case.
2) Records
a) Evaluate the company's pay system and records to determine if workers are paid at least the legal minimum wage applicable in the country of operation or
the amount specified in worker contract.
b) Document review needs to be for at least three months (Average, peak and low activity months) and for all workers in the statistical sample.
c) For each of the months specify in report the minimum wage, and the average wage for obvious worker categories.
d) Look for deductions from workers' pay that can reduce compensation to below minimum wage.
e) Assess the impact of the production system on pay – verify that production targets do not drag workers below the legal minimum wage.
f) Review payroll records and look for the lowest compensation totals to determine all mandated pay and benefits are provided.
g) Bank transfer records, or other equivalent proof of payment, which includes date and amount due for each worker
3) Student workers/interns/apprentices must be reviewed as a separate category

35 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
1. ≥20% of sample is paid less than agreed* wage No policy is in place AND one or more of the 1. No policy is in place, but calculations and Not Applicable
following is true: payment conform to legal requirements,
1. Wage calculations have structural calculation contract or RBA requirements
error
2. Percentage of sample workers paid below
agreed* wage is ≥5% and ≤20%
3. Percentage of sample or population not paid
benefits or correct overtime compensation is
≥5%
Remote Verification Acceptable: NO

36
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A4.2 For each pay period, workers are paid on a timely basis and provided with understandable wage statements that includes sufficient
information to verify accurate compensation for work performed.
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Records
a) Workers are provided with payroll receipts that clearly indicate compensation, including overtime hours and overtime
compensation levels and detail of deductions (e.g. insurance contributions, employer and worker contributions, …)

Additional assistance:
Site Observations Record Review
Not Applicable 1) Records
a) Review evidence that workers are given information relating to wages in an understandable form.
b) Verify for statistical sample and for a minimum of three months:
i) worker signatures on pay registers
c) In most countries, the law states the requirement of the employer to contribute a portion of worker's wages to
national or private insurance schemes. These generally consist of retirement, unemployment, accident, medical and
possibly others. These needs to be communicated to workers and reflected on worker wage receipts.
d) RBA DOES NOT accept a signed agreement with a worker that allows to deduct the social insurance as conformance
option to legal social insurance compliance.

37 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
1. Payments have been delayed for more than 1 One or more of the following is true: One or more of the following is true: Not Applicable
month beyond regular payment cycle 1. Wages and compensation are not 1. Communication and training are provided but
communicated to workers in the form of pay >5 percent of the worker sample do not
slips, pay roll receipt or equivalent understand how wages are calculated
2. No training or explanation of wages are 2. Payments have been delayed less than one
provided to workers month beyond normal payment cycle and for ≤
3. Payments are delayed less than one month 5 percent of worker sample
beyond normal payment cycle and for >5
percent of worker samples

Remote Verification Acceptable: YES

38
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A4.3 Wages are not deducted or reduced for disciplinary reasons
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Policy
a) Adequate and effective policies and procedures prohibiting disciplinary wage deductions are in place including
“Pay equals time worked”
2) Records
a) Disciplinary records pay slips and payment records of wages or equivalent not show any form of disciplinary
wage deduction

Additional assistance:
Site Observations Record Review
1) Policy
a) “Pay equals time worked” applies, this means that if a worker is late the impact on its wages can be no more
than the time the worker was late
2) Records
a) Evaluate for 3 months the statistical sample on Disciplinary records, pay slips and payment records of wages
or equivalent

Rating:
Priority Major Minor Not Applicable
Not Applicable 1. Wage deductions are employed by the Auditee 1. Wage deductions are not employed by the Not Applicable
as a standard disciplinary measure Auditee however no clear policy statement on
this is in place

Remote Verification Acceptable: NO

39 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A4.4 Deductions or withholdings are calculated correctly and submitted to the appropriate government agency within the local law
time frame
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Records
a) Calculations: Records of employer contributions to worker insurance schemes, e.g. unemployment, retirement/pension, health/medical, life,
accident, disability, ... are available on a monthly basis that:
i) Allows for analysis by individual worker
ii) Total per contribution type.
b) Payment: Payment records for these contributions are available for at least 12 months and payments are made timely.

Additional assistance:
Site Observations Record Review
1) Records
a) Verify for at least 3 months statistical sample documents to demonstrate regulatory deduction, payment and communication to worker.
b) Withholdings for taxes and other government programs should be made promptly to the applicable agency. In most countries, the law states
the requirement of the employer to contribute to national or private insurance schemes. These generally consist of retirement, unemployment,
accident, medical and possibly others.
c) RBA DOES NOT accept a signed agreement with a worker that allows to deduct the social insurance as conformance option to legal social
insurance compliance.

40 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
1. Payment of government or regulatory One or more of the following is true: One or more of the following is true: 1. No withholdings or required contributions
deductions have not been made or paid on time 1. Percentage of sample or population that do not 1. Percentage of sample or population that do
for at least 3 months have correct required employer and employee not have correct required employer and
contributions paid is ≥ 20% (excluding new employee contributions paid is <20%
workers less than 2 pay cycles with the (excluding new workers less than 2 pay
employer). cycles with the employer).
2. Required employer and employee 2. Required employer and employee
contributions are not paid regularly or timely contributions are paid timely but not
communicated to workers.
Remote Verification Acceptable: YES

41 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 A5) Humane Treatment
There is to be no harsh or inhumane treatment, including violence, gender-based violence, sexual harassment, sexual abuse, corporal
punishment, mental or physical coercion, bullying, public shaming or verbal abuse of workers; nor is there to be the threat of any
such treatment. Disciplinary policies and procedures in support of these requirements shall be clearly defined and communicated
to workers.

42|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A5.1 No evidence of harsh or inhumane treatment, including violence, gender-based violence, sexual harassment, sexual abuse, corporal
punishment, mental or physical coercion, bullying, public shaming or verbal abuse of workers
Conformance Requirements:
Site Observations Record Review
1) No identification of possible instances of inhumane treatment 1) Records
a) Grievance records do not show instances of inhumane treatment
b) If instances are found appropriate corrective actions are taken immediately and documented
c) Disciplinary records do not show inhumane disciplinary measures

Additional assistance:
Site Observations Record Review
1) Inhumane treatment includes harsh or inhumane treatment, including violence, gender-based violence, sexual
harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying, public shaming or verbal
abuse of workers.

Rating:
Priority Major Minor Not Applicable
1. One or more case of inhumane treatment is 1. Less than two (2) inhumane treatment cases 1. Less than two (2) inhumane treatment cases Not Applicable
reported without action taken by Auditee are reported with actions still in progress were reported with actions completed but no
management measures on an ongoing basis.

Remote Verification Acceptable: NO

43 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A5.2 Adequate and effective policies and procedures on decent/humane working conditions and fair treatment of workers are
established
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Policy
a) Adequate and effective policies and procedures on humane treatment are in place

Additional assistance:
Site Observations Record Review
Not Applicable 1) Policy
a) Inhumane treatment includes harsh or inhumane treatment, including violence, gender-based violence, sexual
harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying, public shaming or verbal
abuse of workers

Rating:
Priority Major Minor Not Applicable
Not Applicable 1. No disciplinary policy/procedures 1. Disciplinary policy and disciplinary action Not Applicable
records are but incomplete
Remote Verification Acceptable: NO

44 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A5.3 Disciplinary actions are recorded, consistent with the procedures and reviewed by management
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Records
a) Records of all cases of disciplinary action are available for last 12 months
b) All records of disciplinary action against workers must be reviewed by management and verifiably
communicated to them
c) Disciplinary records show disciplinary actions with signature or confirmation of worker

Additional assistance:
Site Observations Record Review
1) Policy
a) Inhumane treatment includes harsh or inhumane treatment, including violence, gender-based violence, sexual
harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying, public shaming or verbal
abuse of workers

Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: 1. Disciplinary action records are available, but Not Applicable
1. Disciplinary action records are not available workers do not confirm or sign the
2. Disciplinary action records are not consistent records/actions
with company procedures

Remote Verification Acceptable: YES

45
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 A6) Non-Discrimination/Non-Harassment
Participants should be committed to a workplace free of harassment and unlawful discrimination. Companies shall not engage in
discrimination or harassment based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or
national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic
information or marital status in hiring and employment practices such as wages, promotions, rewards, and access to training.
Workers shall be provided with reasonable accommodation for religious practices. In addition, workers or potential workers
should not be subjected to medical tests, including pregnancy or virginity tests, or physical exams that could be used in a
discriminatory way. This was drafted in consideration of ILO Discrimination (Employment and Occupation) Convention (No.111).

46
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A6.1 No evidence of discrimination
Conformance Requirements:
Site Observations Record Review
1) No visible instances of discrimination 1) Human resources process:
a) Application questions and testing should not exist/occur which are not required OR are necessary to evaluate
the candidate’s fitness for the job
b) Hiring and termination records confirm the candidate's ability to perform the job's requirements.
c) Job postings and advertisements do not discriminate.
d) Job descriptions: Written job descriptions that focus solely on occupational qualifications, not personal
characteristics are in place.
2) Medical tests:
a) Workers or potential workers are not subjected to medical tests that could be used in a discriminatory way.
b) Health tests, pregnancy or virginity testing, or contraception are not used as a condition of employment.
3) Pregnancy/Maternity/Paternity:
a) All conditions regarding pregnancy and postnatal employment protections, benefits, and pay are met
4) Personnel records:
a) Hiring records, promotion records, pay roll, general training and disciplinary records for statistical sample are
reviewed for consistency of policy and to look for evidence of discrimination including hiring, wages, promotions,
rewards, and access to training.

Additional assistance:

47 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 Site Observations Record Review
1) Medical tests:
a) In some cases, local governments require health tests for foreign workers prior to issuance of work visas.
b) No discrimination on the basis of a person’s medical status, make any employment decisions that negatively
affect the person’s employment status unless such decision is dictated by the inherent requirements of the job
or is prudent for workplace safety.
c) No discrimination against a worker in eligibility for another position based on the worker’s refusal to take a
medical test where there is no required medical test for such position.
2) Pregnancy/Maternity/Paternity:
a) Review for discrimination based on pregnancy tests, maternity and paternity leaves:
i) Refuse to hire an applicant for a non-hazardous position; or
ii) Terminate a worker’s employment solely based on the worker’s pregnancy, virginity or parental status.
3) Discrimination cases are applicable if these cases have a documented basis, allegations are not considered as a
discrimination case.
4) Trade union member discrimination based on their trade union status is listed in A7.4

Rating:
Priority Major Minor Risk of Non-Conformance Not Applicable
1. Management discriminates in a 1. Two or more discrimination cases 1. One discrimination case was 1. Discrimination case allegations Not Applicable
structural way that causes are reported with actions not reported with actions completed exist which are open (not
significant harm to a protected taken. but no preventative measures on investigated/ closed).
class. an ongoing basis Discrimination exists because of
current legal provisions in the
country of operation.

Remote Verification Acceptable: NO

48 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A6.2 Adequate and effective policies and procedures that ban discrimination and harassment are in place.
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Policy
a) Adequate and effective policies and procedures that ban discrimination are established.
i) Decisions in hiring, employing (such as compensation, promotion, access to training, …), or terminating
workers are based solely on the candidate's ability to perform the job's requirements.
ii) Auditee periodically reviews hiring practices, compensation records, employee evaluation and promotion
documents, training records, employee benefits policies and procedures, and termination/disciplinary
records to determine that there is no prohibited discrimination.

Additional assistance:
Site Observations Record Review

Rating:
Priority Major Minor Not Applicable
Not Applicable 1. No non-discrimination policy 1. Non-discrimination policy in place, but does Not Applicable
not protect all RBA-protected classes
Remote Verification Acceptable: YES

49 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A6.3 Reasonable accommodation for religious practices is provided.
Conformance Requirements:
Site Observations Record Review
1) In countries and/or workplaces where a significant 1) Policy
percentage of the workers require prayer spaces to a) Adequate and effective policies and procedures are in place to reasonably accommodate for religious practices and adjustments
perform religious observances; clean and safe prayer to the work environment to allow a worker to comply with their religious beliefs while at work or in the job application process.
/religious areas are provided. b) A mechanism for receiving religious accommodation requests is in place
2) Records
a) Requests are kept, reviewed and decision and reason of decision of accommodation (or no accommodation) is provided to the
requestor in a timely manner.
3) CBA
a) Granting a religious accommodation should be evaluated against the Collective Bargaining Agreement (CBA - if in place) and may
vary from the CBA.

Additional assistance:
Site Observations Record Review
1) Policy
a) The procedures must reasonably accommodate group or individual religious practice requests made to management and
may include:
(1) Scheduling Changes
(2) Voluntary Substitutes and Shift Swaps
(3) Change of Job Tasks and Lateral Transfer
(4) Dress and Grooming Standards
(5) Use of Employer Facilities
(6) Tests and Selection Procedures
b) Reasonable Religious Accommodation may be refused for safety and security concerns, after seeking alternatives (including
off-site options) and/or significant impact on business operations, operating costs or other workers.
2) CBA
a) Dialogue with worker representatives is held if there is a difference between the religious accommodation and the CBA, if
this does not violate the privacy of the Reasonable Religious Accommodation requestor.
3) To provide reasonable accommodation for religious practices, a facility is expected to take reasonable measures to ensure that
every worker is not discriminated against based on established religion. Where significant numbers of followers of a religion
require special accommodation to perform their religious obligations, the facility should work to take extra steps to provide space,
time, and flexibility to allow these individuals to meet their religious obligations (e.g. absent from work by taking annual paid or
unpaid leave to perform religious obligations or adjustment of work hours)

50 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
1. Reasonable Religious Accommodation One or more of the following is true: 1. Reasonable Religious Accommodation Not Applicable
requests are refused by management without 1. No policy or adequate Reasonable Religious records (application and responses) are not
justification Accommodation in place kept
2. Prayer /religious areas are provided but not
safe, clean or adequate
3. Reasonable Religious Accommodation
requests are made but not evaluated or
decisions are not communicated to
requestor/workers

Remote Verification Acceptable: NO

51
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 A7) Freedom of Association
In conformance with local law, participants shall respect the right of all workers to form and join trade unions of their own choosing,
to bargain collectively and to engage in peaceful assembly as well as respect the right of workers to refrain from such activities.
Workers and/or their representatives shall be able to openly communicate and share ideas and concerns with management
regarding working conditions and management practices without fear of discrimination, reprisal, intimidation or harassment

GENERAL NOTES
• The reference to “trade union” throughout this guidance refers to trade unions, union, and other worker
representational bodies.
• For sake of brevity, the audit guidance focuses on the right of workers to form and join trade unions of their own
choosing, to bargain collectively, and to engage in peaceful assembly. The audit guidance should also be read to
encompass the rights of workers to refrain from forming and joining trade unions, collective bargaining, and peaceful
assembly.
• Neutrality statement: The auditee company is responsible for ensuring their workers can exercise their rights to
organize in a climate free of violence, pressure, fear, and threats. Auditee Company is not required to take an active
role in supporting workers’ efforts to associate or organize.

52|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A7.1 Workers can form or enroll in a trade union of their own free will
Conformance Requirements:
Site Observations Record Review
1) No evident presence of violence and explicit threats of 1) Policy
any kind a) Adequate and effective policies and procedures that respect that the right of workers to form or enroll in a trade union, or to
2) No evidence present of management’s control of a refrain from doing so, are in place
trade union exists b) No interference: Policy must include that the Auditee will not interfere with and will not finance a trade union
2) Records/minutes
a) There are no documented episodes of violence, explicit threats of any kind or any other violations of the right to freedom of
association.
b) Trade union meeting minutes and financial records for 12 months, if available, to determine source of funding and materials;
c) Management contributions are limited to providing meeting space and/or meeting materials (such as note taking material);
d) Payroll records confirm that trade union employees are paid the same as other workers in similar job functions

Additional assistance:
Site Observations Record Review
1) Policy
a) Workers can form or join a trade union (or refrain from doing so) and are allowed to organize independently of management.
Management must not interfere in the process by directly or indirectly conducting elections related to the formation,
recognition or governance of a trade union. The absence of trade union does not automatically mean a non-conformance, refer
to the rating for guidance.
b) Management should not dominate or interfere with the formation or administration of any trade union or contribute support,
either financial or human resources. Where legally required, management will permit the democratic election of worker
representatives.

Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: 1. Policy/Communication on Freedom of Not Applicable
1. Freedom of Association is prohibited in Auditee communication Association not communicated to or not in a
2. No specific policy or language in general policies that respects language understood by the worker
the right of the workers to form or enroll in a trade union
3. Any grievance or legal finding that the Auditee interfered with
workers Freedom of Association is not acted upon
4. Auditee controls or attempts to control a trade union at the
Auditee’s facility.
5. Evidence that Auditee provides payments or other items of value
to a trade union or the trade union’s leadership or members.
Remote Verification NO
Acceptable:

53 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 54
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A7.2 Legal rights of all workers to bargain collectively, or refrain from doing so, are respected
Conformance Requirements:
Site Observations Record Review
1) No evidence of refusal by management to enter into negotiations upon 1) Policy
request by the trade union certified to represent workers a) Adequate and effective policies and procedures on collective bargaining including the recognition of the right of
workers to bargain collectively, or refrain from doing so
2) Records/meeting minutes
a) No evidence of refusal by management to enter into negotiations upon request by the trade union
b) Auditee participates in good faith in the collective bargaining process with the trade union certified to bargain
on behalf of the workers;
3) CBA
a) The Collective Bargaining Agreement terms and conditions are implemented

Additional assistance:
Site Observations Record Review
1) CBA
a) If the Collective Bargaining Agreement terms and conditions are not implemented or met please list the finding
in the appropriate provision

Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: Not Applicable No CBA in place.
1. Material elements of the CBA are not upheld
and there is no evidence that management is
acting to remediate;
2. Evidence that the CBA process is prohibited

Remote Verification Acceptable: NO

55 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A7.3 Participants respect the legal right of all workers to peacefully assemble as well as respect the right of workers to refrain from
doing so.
Conformance Requirements:
Site Observations Record Review
1) No signs of explicit prohibition of the right of peaceful assembly. 1) Policy
a) Adequate and effective policies and procedures on peaceful assembly are in place noting the right of workers;
individually or collectively; to express, promote, pursue, and defend their concerns or ideas; or to refrain from
doing so
2) Records/meeting minutes
a) Respects the right of workers to individually or collectively; to express, promote, pursue, and defend their
concerns or ideas as well as respect the right of workers to refrain from doing so
b) Does not interfere with, restrain, or coerce workers in the exercise of their right to individually or collectively;
to express, promote, pursue, and defend their concerns or ideas or to refrain from doing so

Additional assistance:
Site Observations Record Review
1) Policy
a) May place reasonable time, place, and manner controls regarding assembly for purposes of maintaining a
healthy, safe, and productive work environment

56 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: 1. Communication about the right of workers to Not Applicable
1. Right of workers to individual or collectively individual or collectively raise concerns or
raise concerns or ideas is not recognized in ideas is made, but not in a language
policy and/or has not been upheld in practice understood by the worker
2. Right of workers to individual or collectively
raise concerns or ideas process is prohibited in
Auditee communication

Remote Verification Acceptable: NO

57
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
A7.4 No evidence of unequal treatment between unionized or worker representatives and other workers exists
Conformance Requirements:
Site Observations Record Review
1) No evident presence of a prohibition of association with a trade union 1) No evidence that Auditee dismisses, disciplines, or explicitly threatens workers in order to encourage or discourage
workers from forming or joining a trade union, or refraining from doing so

Additional assistance:
Site Observations Record Review
1) Payroll; promotion; training; disciplinary; hiring and termination records do not indicate any form of discrimination
between workers;
2) Management should not discriminate against workers with respect to hiring, termination, or any other term or
condition of employment in order to encourage or discourage workers from forming or joining a trade union or
refraining from doing so. Differences in terms and conditions of employment between unionized and non-union
workers due to a collective bargaining agreement negotiated between management and a duly recognized trade union
on behalf of certain workers does not constitute discrimination.
3) Any other form of discrimination must be listed in A6.1

58 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: 1. One case exists where the mechanism to 1. No union (not unionized) or worker
1. Mechanism to report and resolve report and resolve discrimination is representative
discrimination is ineffective (two or more ineffective
cases)
2. Differences in pay; promotion; training;
discipline; hiring and termination records
encourage or discourage workers from
forming or joining a trade union, or encourage
or discourage workers to refrain from doing so

Remote Verification Acceptable: NO

59
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
3. B. HEALTH & SAFETY

GENERAL NOTES
• For facilities with significant EHS risks an EHS expert Auditor will be added to the audit team for an expert review of these policies, programs,
and performance.
• Where monitoring, testing, audits or other assessments are required and law, licenses or permits are silent on the frequency, then the frequency
must not exceed three years unless there are Significant Changes to the process, facility or product use.
• A risk assessment must be updated if there is a Significant Change.

B1) Occupational Safety

Worker potential for exposure to health and safety hazards (e.g. chemical, electrical and other energy sources, fire, vehicles, fall
hazards, etc.) are to be identified, assessed and mitigated using the Hierarchy of Controls, which includes eliminating the hazard, substituting
processes or materials, controlling through proper design, implementing engineering and administrative controls, preventative
maintenance and safe work procedures (including lockout/tag out), and providing ongoing occupational health and safety training.
Where hazards cannot be adequately controlled by these means, workers are to be provided with appropriate, well-maintained,
personal protective equipment and educational materials about the risks to them associated with these hazards. Reasonable steps
must also be taken to remove pregnant women/nursing mothers from working condition with high hazards, remove or reduce any
workplace health and safety risks to pregnant women and nursing mothers including those associated with their work assignments,
and provide reasonable accommodations for nursing mothers.

60|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
B1.1 All required permits, licenses and test reports for health & safety is in place and a process is implemented to ensure permits and
licenses are up to date at all times
Conformance Requirements:
Site Observations Record Review
1) License related to special equipment, such as crane, 1) Process
boiler, forklift, are placed at the working area a) A documented process is in place to ensure permits are renewed before current permits expire
2) Records
a) All required occupational health & safety permits and licenses are in place, available for review and valid.
a) Occupational health & safety testing reports are in place, available for review.
3) Drinking water
a) Drinking water testing reports are available for review. Water must be tested for those contaminants assessed to be at risk for the
local region and operations.

Additional assistance:
Site Observations Record Review
1) Process
a) A documented process e.g. a compliance calendar or reminders/tasks/calendar appointments via an e-mail system.
2) Records
a) All occupational health & safety permits and licenses e.g.
i) Building occupancy permits
ii) Pressure vessel (e.g. boiler) permits
iii) Hoist permit
iv) Lift permit
b) Occupational health & safety testing reports e.g.
i) Industrial hygiene sampling data
ii) Drinking water sampling data
iii) Ventilation flow tests
3) Drinking water
a) Drinking water testing is not required if local water utility company can attest water meets World Health Organization (WHO) Guidelines
for Drinking-water Quality or equivalent standard
b) Permits and testing (e.g. drinking water testing) related to sanitation, food and drinking water are covered under B7.1.

61 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One or more of the following is true: 1. No permits or license required. No
1. Required permits, licenses or testing reports 1. Required permits, licenses or testing reports testing reports required.
missing in place but the process to secure and renew
2. Two or more of minimum requirement as required is not sufficiently documented or
elements are missing or ineffective. is missing some components
2. One of minimum requirement elements is
missing or ineffective, or a system element is
not adequately documented or is prohibited

Remote Verification Acceptable: YES

62 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
B1.2 Potential for worker exposure to health & safety hazards (e.g. chemical, electrical and other energy sources, fire, vehicles, and
fall hazards) identified, assessed and mitigated using the Hierarchy of Controls.
Conformance Requirements:

Site Observations Record Review

1) Controls 1) Adequate and effective process to identify,
a) Engineering controls are used where appropriate assess, and mitigate using the Hierarchy of
2) Building Controls potential worker health & safety
a) Buildings are structurally sound hazards
b) Confined spaces are identified. 2) Controls
3) Chemical a) Safe works practices are established and
a) Chemicals are adequately and effectively documented where engineering controls
i) Categorized are not feasible or do not completely
ii) Handled control the hazard.
iii) Stored b) Confined spaces hazards are evaluated
iv) Moved within the facility. before workers are allowed to enter
b) Control c) A hot work permit system is in place for
i) Access to hazardous substances is controlled welding, cutting and brazing.
ii) Potential employee exposure methods are adequate and effective such as d) A safety inspection is performed daily or
iii) Segregation prior to each use for all industrial
iv) Secondary containment powered vehicles
v) Ventilation e) Electrical installations and wiring are
vi) Fire protection regularly inspected and maintained to
vii) Appropriate storage cabinets prevent electrical shock hazards
4) Fall (damaged cords and plugs, frayed wiring,
a) Stairways and elevated work areas are provided with appropriate guardrails and handrails and elevated work platforms are rated for load missing protective barriers, ...)
capacity f) Lockout/tag out program is in place for
b) Aisles, stairways, and work areas are free of tripping hazards (stored materials, electrical cords, ...) work on equipment where stored energy
c) Workers are provided with appropriate fall protection for work in elevated work areas (roof work, high lift fork trucks, towers, ...). Buildings (electrical, pneumatic, mechanical, …) or
are facilitated with tie-off points to provide workers with safe anchor points in the event that they need to attach a harness. inadvertent start-up could injure workers
5) Electrical and other energy sources 3) Evaluation
a) Precautions and controls of electrical hazards are in place such as locked cabinets, closed panels, unobstructed access a) Documentation of procedures includes
b) Energized parts are protected from accidental contact by enclosures and barriers and all protective methods are in place and not deficient how the program is evaluated and
6) Vehicle implemented
a) In areas where powered industrial vehicles are used, pedestrian walkways are clearly delineated and physically separated, where possible,
from vehicle operation areas
7) Fire
a) Combustible storage is minimized and limited to areas with adequate fire detection and protection.

63 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 b) Flammable and combustible materials are properly stored to prevent the accumulation of vapors. Ignition hazards (e.g. smoking, electrical
sparks, open flames, ...) are eliminated in areas where combustible and flammable materials are stored or used or if there is a flammable
atmosphere
Additional assistance:
Site Observations Record Review
1) Hazardous chemicals are covered in C3.1

Rating:
Priority Major Minor Not Applicable
1. Imminent risk of loss of facility, life or limb One or more of the following is true: One or more of the following is true: Not Applicable
1. One or more occupational safety hazards do 1. Control to limit worker exposure to
not have control measures to limit worker occupational safety hazards in place but not
exposure regularly monitored
2. Safety concerns are not evaluated or 2. One of minimum requirement elements is
addressed missing or ineffective, or a system element is
3. Fire risks identified were not addressed (e.g. not adequately documented or is prohibited
bad wiring, housekeeping of combustible
materials, overloading in electricity)
4. Two or more of minimum requirement
elements are missing or ineffective.

Remote Verification Acceptable: NO

64
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
B1.3 Appropriate Personal Protective Equipment (PPE) is consistently and correctly used where required to control health & safety
hazards and worker exposure
Conformance Requirements:
Site Observations Record Review
1) PPE requirements 1) PPE is free of charge
a) PPE selection is appropriate for the given hazard 2) PPE process
b) PPE requirements should be communicated to employees via posted a) Adequate and effective process is implemented to assess worker health & safety hazards and determine
signs and worn by all affected people either performing those tasks or appropriate PPE for specific job tasks and/or areas of the facility.
in the areas that require PPE b) PPE requisition and renewal procedures
c) Workers preforming tasks that require PPE do so according to PPE c) Adequate and effective notification and enforcement process for PPE use is in place
procedure requirements 3) Records
2) PPE availability a) PPE adequacy evaluation records
a) PPE should be made available b) PPE inventory and replacement records
b) PPE is in good and working condition c) PPE inventory, and logs to have new PPE
c) PPE is appropriately stored and accessible d) Job specific PPE matrix
e) Fit test record for respiratory protection equipment
f) Wage records do not show a fee or charge for PPE

Additional assistance:
Site Observations Record Review
1) PPE requirements 1) PPE process
a) Minimum PPE requirements for entering or working in any production a) Hazards such as high noise, chemical use including open surface tank operations, heavy equipment use,
area with open surface tanks of hazardous chemicals where there is awkward positions, work at heights, overhead hazards, etc. should all be evaluated
a risk of contact with or exposure to the contents of the tank include b) PPE notification and enforcement process could include:
respirators appropriate to the level and type of inhalation exposure (if i) Signs and labels
necessary), safety shoes, long sleeves, chemically resistant gloves, ii) Regular enforcement by supervisors
and eye protection (e.g. a full-face shield and safety goggles). iii) Work area inspections
2) PPE availability 2) Records
a) PPE should be made available and worn appropriately by all who work a) PPE monitoring records
or reside in this area for long periods of time (longer than exposure b) PPE cleaning records
limit value) 1) PPE notification finding must be covered in B8
2) PPE includes all Occupational Health & Safety and Industrial Hygiene PPE

65 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
1. PPE is not worn, is not available to workers, One or more of the following is true: 1. PPE is worn in required areas, but no 1. No PPE is required.
is worn incorrectly, or is the wrong type of 1. PPE is not worn inspection program on safe/valid use of PPE
PPE AND there is immediate risk to workers 2. PPE is not worn correctly in required areas or
while performing tasks that require PPE
3. PPE is not in good condition / working order,
sufficient, visible or easily accessible

Remote Verification Acceptable: NO

66
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
B1.4 Reasonable steps are in place to remove pregnant women/nursing mothers from working conditions with high hazards, minimize any
workplace health and safety risks to pregnant women and nursing and provide reasonable accommodations for nursing mothers
Conformance Requirements:
Site Observations Record Review
1) Pregnant workers are not working in job which has a hazard to the pregnant 1) General Policy
worker and her child a) Adequate and effective policies and procedures are in place to minimize the Health & Safety impact in pregnant
2) Reasonable accommodations for nursing mothers are in place woman and nursing mothers
2) Risk assessment
a) Adequate and effective risk management process is in place to:
i) Before a pregnancy is reported: assess the potential hazards to expecting mothers
ii) After pregnancy is reported: a worker-specific risk assessment of the worker’s job to assess risk to mother
and fetus
iii) After mother returns to work: a worker-specific post-natal risk assessment of the worker’s job to assess
risk to mother and possible impacts on the baby through breastfeeding
iv) All reasonable efforts must be made to minimize the risk identified in each of the 3 risk assessments
3) Reasonable accommodation to nursing mothers
a) Provide reasonable break time for a worker to express breast milk for her nursing child for one year after the
child's birth each time such worker has need to express the milk.
b) Provide a place, other than a bathroom, that is shielded from view and free from intrusion from coworkers and
the public, which may be used by an employee to express breast milk
4) Records
a) Personnel files contain specific to worker pre- and ante-natal risk assessment and actions taken in line with
policy
b) General risk assessment for pregnant workers reports and actions taken (if any needed) are available for review

67 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Additional assistance:
Site Observations Record Review
1) General Policy
a) Applies to all types of workers (direct, indirect, dispatched, young, interns, apprentices, …)
2) Risk assessment
a) General and specific to worker risk assessment must include assessment of:
i) Lifting/carrying heavy loads;
ii) Standing or sitting still for long lengths of time;
iii) Exposure to infectious diseases
iv) Exposure to lead;
v) Exposure to toxic chemicals;
vi) Work-related stress;
vii) Workstations and posture;
viii) Exposure to radioactive material;
ix) Threat of violence in the workplace;
x) Long working hours;
xi) Extreme heat
xii) Excessive noise
xiii) Night shifts
b) Ante-natal risk assessment must include:
i) Working with organic mercury;
ii) Working with radioactive materials;
1) Exposure to lead
3) Reasonable accommodation to nursing mothers
a) Location does not need to be a separate dedicated area
b) Location for breastfeeding activities:
i) Not be a toilet stall or a bathroom
ii) Private;
iii) Close to the workspace
iv) Clean
v) Secure
vi) Has a water supply (e.g., a sink)?
vii) Has access to hygienic storage (e.g. a closed clean cupboard)
viii) Breaks for expressing milk (pumping breaks) are not compensated unless paid breaks are used to express
milk

68 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
1. Pregnant workers are present and working One or more of the following is true: One or more of the following is true: 1. All male facility/operation
with immediate risk to worker and child 1. No general Policy 1. A General Policy is in place but in complete
2. No risk assessment for pregnant workers and 2. A risk assessment for pregnant workers and
nursing mothers (2 or more elements nursing mothers is in place and performed
missing) but incomplete (not all elements evaluated or
3. No reasonable accommodation provided for some action incomplete)
nursing mothers (2 or more elements 3. No reasonable accommodation provided for
missing) nursing mothers but does not meet all criteria

Remote Verification Acceptable: NO

69
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 B2) Emergency Preparedness
Potential emergency situations and events are to be identified and assessed, and their impact minimized by implementing emergency
plans and response procedures, including: emergency reporting, employee notification and evacuation procedures, worker training
and drills. Emergency drills must be executed at least annually or as required by local law whichever is more stringent. Emergency plans should
also include appropriate fire detection and suppression equipment, clear and unobstructed egress, adequate exit facilities, contact
information for emergency responders, and recovery plans. Such plans and procedures shall focus on minimizing harm to life, the
environment and property.

70|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
B2.1 All required permits, licenses and inspection/testing reports for fire safety response equipment (including fire suppression
equipment) and emergency preparedness are in place and a process is implemented to ensure permits and licenses are up to date at
all times
Conformance Requirements:
Site Observations Record Review
Posting of emergency numbers/procedures 1) Process
a) A documented process is in place to ensure permits are renewed before current permits expire
2) Records
a) All required occupational safety permits and licenses are in place, available for review and valid.
b) Occupational safety testing reports are in place, available for review

Additional assistance:
Site Observations Record Review
1) Process
a) A documented process e.g. a compliance calendar or reminders/tasks/calendar appointments via an e-mail
system.
2) Records
a) All occupational safety permits and licenses e.g.
i) Fire safety and emergency preparedness
b) Occupational safety testing reports e.g.
i) Fire safety inspection data
ii) Emergency preparedness data

71 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One of minimum requirement elements is missing No permits or license required. No
1. Required permits, licenses or testing reports or ineffective, or a system element is not testing reports required
missing adequately documented or is prohibited
2. Two or more of minimum requirement
elements are missing or ineffective.

Remote Verification Acceptable: YES

72
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
B2.2 Adequate and effective fire detection, alarm and suppression systems are in place.
Conformance Requirements:
Site Observations Record Review
1) Detection 1) Process
a) Automatic heat and/or smoke detection as required by insurance a) Automatic fire sprinklers (if required by law or insurance company), portable fire extinguishers, heat and smoke
company detection, and an alarm and notification system are inspected, tested and maintained for good state of operation
b) Detector devices and system are in function on a regular basis, as required by insurance company or common practice
2) Alarm 2) Records
a) All buildings have a manual or automatic fire alarm and notification a) The inspection frequency for portable fire extinguishers shall not be less than monthly. The inspection frequency
system for single unit smoke detectors shall not be less than semi-annually.
b) Fire alarm control system is free of trouble/supervisory signals b) Inspection for all other fire safety equipment, testing and maintenance frequency shall not be less than that
(trouble/supervisory signals are usually indicated by orange LED required/recommended by the manufacturer, local code or insurance company whichever is more stringent
lights). c) The inspection, testing and maintenance procedure, frequency and results are documented
c) Fire alarm manual call-points or pull-stations are provided at or along
egress routes to exits
3) Fire suppression
a) Portable fire extinguishers are installed, with unimpeded access
b) Fire extinguisher inspection tags
c) automatic fire sprinklers as required by insurance company
d) Fire hose inspection tag,
e) Fire water tank and water pressure are normal

73 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Additional assistance:
Site Observations Record Review
1) Fire suppression 1) If an insurance inspection has occurred within the last 12 months, ask to see a copy. Any issues/concerns noted in
a) Normally open sprinkler control valves are locked in fully open the insurance inspection report have an agreed corrective action plan. The agreed corrective action plan is on track.
position. Fire pumps are set to run automatically. Large ducts or Or if off-track additional measures have been identified to bring it back on track.
objects do not obstruct sprinkler heads. Fire extinguishers are in their
designated locations, fully charged and free of signs of tampering and
have evidence (tags) that indicate they have been inspected.
b) Asbestos-containing fire-suppression materials—for example,
blankets—are prohibited.

Rating:
Priority Major Minor Not Applicable
One or more of the following is true: One or more of the following is true: One or more of the following is true: Not Applicable
1. No firefighting equipment 1. Firefighting equipment AND automatic 1. Systems are in place and inspection, testing
2. No sprinkler or automatic detection system (if detection system AND alarm or notification and maintenance procedures are documented
required) systems are in place but not inspected, tested and implemented but the results are not
3. No alarm or notification system is in place and maintained as required by minimum recorded
4. Firefighting equipment AND automatic requirements. 2. Isolated case of any single component (e.g. fire
detection system AND alarm or notification 2. Firefighting equipment AND automatic extinguisher, detector, …) of the system is not
systems are in place but ≥ 10% is not detection system AND alarm or notification functional however does not represent a
functional systems are in place but <10% is not functional systemic failure.
3. Two or more of minimum requirement 3. One of minimum requirement elements is
elements are missing or ineffective missing or ineffective, or a system element is
not adequately documented or is prohibited

Remote Verification Acceptable: NO

74 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
B2.3 All potential emergencies that could affect the site are identified and assessed, and effective emergency preparedness and
response programs (plans/procedures) are established.
Conformance Requirements:
Site Observations Record Review
1) Signage 1) Risk assessment
a) Adequate and effective signage is observed with emergency a) Adequate and effective risk assessment process is in place considering
number(s), emergency team and emergency plot, evacuation, and i) Harm to life
response plan. ii) The environment
b) Maps are posted throughout the facility which clearly identify exit iii) Property
routes and muster points in the correct orientation b) The risk assessment is current (updated when there is a Significant Change or at least every 3 years)
2) Muster points 2) Business continuity and resumption
a) Muster points have been established in safe locations to enable a) Business continuity and resumption procedures are available, current and adequate
employee accountability during an emergency. 3) Emergency response
3) Emergency response kits a) Documented current emergency response plans (ERP) are in place and available for review reflecting the risk
a) Emergency response kits are easily located and accessible near assessment, including contact information for emergency responders .
muster points b) A post-emergency plan is in place which includes incident reporting, root cause investigation, and
corrective/preventative actions.
4) Records
a) Records are available for review:
i) Risk assessment
ii) Business continuity and resumption
iii) Emergency response
iv) CAPs resulting of post emergency evaluation (if applicable)

75 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Additional assistance:
Site Observations Record Review
1) Muster points 1) Current = reflecting the actual situation of the facility/operation
a) Muster points will be both inside (tornado/extreme weather shelter- 2) Risk assessment
in-place) and outside (fire, chemical release) a) Risk assessment minimum elements:
i) Fire
ii) Chemical spill (if large quantity or especially hazardous chemicals are used)
iii) Earthquake (if in earthquake zone)
iv) Severe weather (rain, flood, typhoon, frost, snow, or other conditions as appropriate to the facility location,
...).
v) Workplace violence
vi) Strike
3) Emergency response
a) ERP minimum elements
i) Specific roles
ii) Available for review upon request by employees.

Rating:
Priority Major Minor Not Applicable
1. No risk assessment One or more of the following is true: One or more of the following is true: Not Applicable
1. No emergency response plan (ERP) in place 1. Risk assessment and ERP up to date and
2. No business continuity and resumption plan in complete but no reporting procedure
place 2. One of minimum requirement elements is
3. ERP is in place but not covering all minimum missing or ineffective, or a system element is
requirements or missing items identified as not adequately documented or is prohibited
significant / major risk in risk assessment
4. Risk assessment, business continuity and
resumption or ERP are not current
5. Workers unaware of ERP
6. Lack of procedure for notification to outside
emergency services
7. Two or more of minimum requirement
elements are missing or ineffective

Remote Verification Acceptable: NO

76 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
B2.4 Effective emergency exit access, exits, and exit discharge are adequate in number and location, readily accessible, and properly
maintained
Conformance Requirements:
Site Observations Record Review
1) Clear and unobstructed egress (i.e. Exit access, exit and exit discharge) 1) Process
a) An adequate number of effective Exit Routes from every area a) Adequate and effective process in place to ensure effective emergency Exit Access,
b) Exit Routes are separated by an appropriate distance and do not share a common exit. exits and Exit Discharge with unobstructed egress in in place
c) Exit Routes are clear of obstructions 2) Records
d) Exit Discharges discharge to open space/parking lot, and do NOT discharge to an a) Inspection records for emergency support facilities (emergency lighting, emergency
enclosed/gated/locked area exit signs, evacuation paths, exit enclosures, ...) are maintained and show these are
e) Exits are free of material storage; and enclosures are not used for any other purpose except for inspected as per insurance requirements, or local practice whichever is stricter.
egress
f) All Exit Route doors (i.e. Exit Access doors, Exit Discharge doors) which serve high occupancy
(=>50) or hazardous areas, open in the direction of egress.
g) All Exit Route doors (i.e. Exit Access doors and Exit Discharge doors) should open without using a
key, badge, code, special knowledge, or effort.
h) All Exit Discharge doors must
i) be a single motion exit or
ii) have Listed Panic Hardware installed which is pushed open in a single motion
2) Exit signs:
a) Exit signs are provided to mark exits on every floor
b) Exit signs are illuminated and/or lighted in the event of a power failure
c) Additional exit and/or directional signs are provided at main passageways/aisles, long corridors
and at other locations where the way to the nearest exit is not clear.
3) Emergency lighting:
a) Emergency lighting provided and installed to illuminate means of egress in the event of a power
failure.
b) Lighting shall provide adequate, functional emergency lighting in stairs, aisles, corridors, ramps,
and passageways leading to exits, and in other areas as required by applicable laws.
c) Either battery or backup generator may power emergency lighting.
4) Separation:
a) Penetrations are limited to sprinkler pipes, standpipes, and electrical services, pipe and duct
installation serving the enclosures
b) Openings into the enclosures are protected by fire rated doors or window
c) Fire doors are in good condition, self-closing or automatic closing (upon fire alarm or detection of
smoke)
d) Integrity of exit enclosures is maintained

77 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Additional assistance:
Site Observations Record Review
1) Non-conforming situations for Exit Route doors (i.e. Exit Access doors and Exit Discharge doors)
include:
a) Multiple steps required to open doors
b) Anything requiring a tight grasp
c) Rolling doors that open vertically
2) On designated Exit Routes, rolling doors shall not be adopted as the designated / marked emergency
Exit Doors. On designated Exit Routes, sliding doors shall not be adopted as the designated / marked
emergency Exit Doors unless there is a safety feature, to be demonstrated in the audit, which allows
the doors to swing to a full-open position in the direction of travel.
3) Auditor must follow at least three randomly selected egress routes out of the building to the
assembly/muster point

Rating:
Priority Major Minor Not Applicable
One or more of the following is true: One or more of the following is true: One or more of the following is true: Not Applicable
1. No emergency support facilities present or in 1. One (1) emergency exit blocked or lacking 1. All emergency support facilities are
good operating condition throughout easy means of egress as defined in Minimum appropriate, in good condition and inspected,
Auditee’s facility Requirements (i.e. require key, badge, code, however inspection records are not
2. Two (2) or more emergency exits are blocked multiple steps or tight grasp or rolling doors) maintained or are incomplete.
or lacking easy means of egress as defined in or Exit Discharge lacking approved Listed 2. One of minimum requirement elements is
Minimum Requirements (i.e. require key, Panic Hardware, or are Exit Discharge doors missing or ineffective, or a system element is
badge, code, multiple steps or tight grasp or which open inward when not permitted... not adequately documented or is prohibited
rolling doors) or lack approved panic 2. Emergency support facilities are generally in
hardware working condition, however, there is at least
one missing component or exception.
3. Emergency support facilities not inspected.
4. Two or more of minimum requirement
elements are missing or ineffective

Remote Verification Acceptable: NO unless a Minor with only gaps in records or

documentation

78
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
B2.5 Adequate and effective fire and other identified emergency situations and evacuation drills are conducted with all employees, and
records are maintained.

Conformance Requirements:
Site Observations Record Review
Not Applicable 1) ERP drill plan
a) Adequate and effective emergency evacuation drill program
i) Fire
ii) Other emergencies
b) Emergency drills must be executed at least annually or as required by local law whichever is more stringent
c) ERP drill plan must include at minimum
i) All workers
ii) Every area (including dormitory, cafeteria, warehouse, office areas, productions floors, research and development laboratories,
shipping/receiving)
iii) All work shifts
iv) One drill that is conducted at night; while it is dark outside)
v) Appropriate frequency (other than fire emergency situations) (frequency determined through the facility risk-assessment see B2.3)
2) Effectiveness evaluation
a) The effectiveness of each drill should be evaluated and documented
b) A Corrective action plan for any deficiencies identified
3) Records
a) Records are available for the last 3 years
i) ERP drill plan
ii) ERP drill evaluation reports
iii) ERP drill CAPs
Additional assistance:
Site Observations Record Review
1) Effectiveness evaluation
a) Effectiveness evaluation includes
i) Time of the drill
ii) Time required to clear the building or otherwise respond to the emergency
iii) Any deficiencies identified during the drill
2) Records
a) Records for last 3 years, including CAP and their status are available for review and spot-checked to ensure corrections are being made
and implemented

79
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
1. No emergency evacuation drill held in last 2 One or more of the following is true: One or more of the following is true: Not Applicable
or more years 1. No emergency evacuation drill held in last 1. Corrective actions from last drilled are off
year or drill was held but not for all areas and track or not being tracked
all shifts and at least one drill at night while it 2. One of minimum requirement elements is
was dark outside. missing or ineffective, or a system element is
2. Drill was held for all areas and all shifts not adequately documented or is prohibited
however post-drill evaluation was not done
3. Drill was held for all areas and all shifts and
post-drill evaluation was done but
corresponding corrective actions were not
determined or documented
4. Two or more of minimum requirement
elements are missing or ineffective

Remote Verification Acceptable: YES

80
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
B2.6 Designated emergency response personnel are provided adequate and effective PPE and training on an annual basis
Conformance Requirements:
Site Observations Record Review
1) Emergency response PPE is available, adequate and in good and working 1) ERT assignment
condition. a) An emergency response team (ERT) is formed at each facility that shall be available during all working shifts
2) Emergency response PPE storage is clearly marked, visible and easily 2) The ERT shall have the obligation and authority to direct the Auditee’s response to emergencies to ensure the
accessible. protection of worker health and safety, the environment, and property
3) Badges, different colored attire/hard-hat, and office/cubicle signage may 3) ERT qualifications
identify emergency response team personnel a) ERT members have the required qualifications
4) ERT training
a) Emergency responders are trained on an annual basis.
b) Training will be dependent on responsibilities during an emergency
c) Training material and training records are available for review and up to date

Additional assistance:
Site Observations Record Review
1) ERT members = workers involved in the control, cleanup and disposal of hazardous materials or other emergency
response procedures (e.g. firefighting)
2) It is expected that the facility will have a designated Emergency Response Team (ERT), and this team will have the
appropriate PPE for their emergency response duties defined in A2.3 (Emergency response). In some cases, an ERT
might not exist, the justification must be available and valid.

Rating:
Priority Major Minor Not Applicable
One or more of the following is true: 1. Two or more of minimum requirement 1. One of minimum requirement elements is 1. No ERT requirement
1. PPE for ERT is not available elements are missing or ineffective missing or ineffective
2. PPE for ERT is not in good condition / working
order, sufficient, visible or easily accessible
3. No ERT in place

Remote Verification Acceptable: YES

81 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 B3) Occupational Injury and Illness

Procedures and systems are to be in place to prevent, manage, track and report occupational injury and illness, including provisions
to: a) encourage worker reporting; b) classify and record injury and illness cases; c) provide necessary medical treatment; d)
investigate cases and implement corrective actions to eliminate their causes; and e) facilitate return of workers to work.

82|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
B3.1 All required permits, programs, licenses, and testing reports for occupational injury and illness are in place and a process is
implemented to ensure permits and licenses are up to date at all times
Conformance Requirements:
Site Observations Record Review
Required postings are current and located in public view. Some signage and 1) Process
information may be required to be posted in employee common/break/cafeteria a) A documented process is in place to ensure permits are renewed before current permits expire
locations. 2) Records
a) All required occupational injury and illness permits and licenses are in place, available for review and valid.
b) occupational injury and illness testing reports are in place, available for review
c) Government certifications, permits, inspections, approval for the onsite medical treatment facility is available
for review
3) Medical professional certificates
1) Valid certificates for occupational health are available for review (e.g. first responders ... where required).
If nurses or doctors are employed or doctor/nurse services are used, a copy of their certificate/license is available for
review

Additional assistance:
Site Observations Record Review
1) Process
a) A documented process e.g. a compliance calendar or reminders/tasks/calendar appointments via an e-mail
system.
1) Records
a) All occupational safety permits and licenses e.g.
i) Occupational health professional licenses
b) Occupational safety testing reports e.g.
i) Injury logs
ii) Respiratory protection (fit tests, medical evaluations)
iii) Hearing conservation programs
iv) Notice of availability of medical records

83
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One of minimum requirement elements is missing No permits, programs, license or testing
1. Required permits, programs, licenses or or ineffective reports required. No testing reports
testing reports missing required.
2. Two or more of minimum requirement
elements are missing or ineffective
Remote Verification Acceptable: YES

84 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
B3.2 Investigations to determine root cause(s) and implement corrective/preventive actions for work-related injuries/illness in the
past three years are performed and documented, communicated to affected employees, and tracked to closure.
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Reporting
a) A system for workers to report health and safety incidents and near misses, as well as a system to investigate, track, and manage such
reports.
b) All reportable and non-reportable accidents are tracked; documented and investigated to minimize the potential for future occurrence.
c) Occupational Injury and illness data for last 3 years are available for review including surveillance data
2) Analysis
a) All accidents are investigated and analyzed for corrective and preventive actions
b) Trend analysis of the occupational Injury and illness data is performed on a regular basis, at least annually and corrective actions are
identified
3) Preventive Action
a) Corrective and preventive actions following accident investigation or trend analysis were implemented (or are on track) and verified as
effective
b) If a worker has abnormal medical surveillance results or is injured immediate appropriate preventive action will be taken

Additional assistance:
Site Observations Record Review
1) Surveillance data= pre-job, on-the-job, post-job, and post-emergency medical data
2) Review number and type of first aid events, number and type of injuries beyond first aid, and any fatalities.
3) Appropriate preventive action as a result of medical surveillance or injury:
a) Worker shall be removed from the current job immediately and offered another position in the facility.
b) Auditee is prohibited from terminating the labor contract with the worker due to the medical surveillance results.
c) Auditee shall provide medical treatment to the worker.
d) Auditee shall provide re-examination to the worker.
e) Auditee shall cover the medical treatment, re-examination, and rehabilitation cost for the worker.

85 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
1. Reportable occupational accidents, injuries and One or more of the following is true: One or more of the following is true: 1. No injuries, accidents or illnesses in the
illnesses are not reported to the governing 1. No accidents, injury and illness are tracked or 1. Accidents, injuries, illnesses tracked, analyzed past 3 years.
agency as required by law incomplete records for last 3 years. and prevented but no formal procedure
2. Accidents are tracked but no analysis, 2. Corrective actions are off track
investigation or corrective actions. 3. One of minimum requirement elements is
3. Two or more of minimum requirement elements missing or ineffective
are missing or ineffective

Remote Verification Acceptable: YES

86 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
B3.3 An effective first aid process and adequate number of first responders are available to provide initial medical treatment for injured
or ill workers is in place
Conformance Requirements:
Site Observations Record Review
1) First Aid responders are easily identifiable by badges, colored attire, 1) Policy
office/work area signage a) Adequate and effective first response policies and procedures are in place indicating severity of medical
2) If applicable, an occupational medical clinic is adequately staffed and emergency and response (first aid, infirmary, local external hospital).
supplied to respond to injuries 2) First Responders
3) If the medical clinic is not open or operated 24 hours per day, alternative a) The facility assigns a team of trained/certified first responders.
resources such as outside medical services are communicated to 3) In-house infirmary or clinic:
employees a) An operations log of onsite emergency occupational medical clinic is available and up to date (access might be
restricted due to privacy laws).
b) Documented procedures and supplies for the onsite occupational medical clinic are available and adequate.

Additional assistance:
Site Observations Record Review
1) Policy
a) Injured workers are then sent to off-site medical facilities for further treatment.
2) First Responders
a) It is possible that the role of trained/certified first responders is performed by onsite medical professional team
3) If first responders do not have adequate training, then list the finding in B8 or B2.6 if they are part of the ERT.

87 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
1. No first responders or procedures One or more of the following is true: 1. One of the minimum requirements is missing Not Applicable
1. First aid, occupational medical clinic or first or infective
response procedures are inadequate 2. Percentage of first responders is <10% below
2. Occupational medical clinic has inadequate the legal required number of first responders.
supplies, staffing or access
3. Percentage of first responders is ≧10% below
the legal required number of first responders

Remote Verification Acceptable: YES

88
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
B3.4 Adequate first response equipment and first aid kits to provide medical treatment for injured or ill workers are available to
employees in designated areas. The kits have adequate supplies and are inspected on a monthly basis.
Conformance Requirements:
Site Observations Record Review
1) First Aid kits 1) Maintenance procedure
a) Appropriate and completely stocked placed /assigned first aid kits are a) Adequate and effective maintenance procedure is in place for inspection, maintenance, upkeep and stocking of
available in designated locations. all first response equipment and first aid kits
b) First aid kits are unlocked or if locked, first responder can access the b) Frequency is at least monthly for all inspections
key at all times. 2) Records
2) First Response Equipment a) First aid kits have inventory list
a) Appropriate and well maintained first response equipment is available b) Inspection tracking records are available and up to date.
in designated locations.

Additional assistance:
Site Observations Record Review
First response equipment = e.g. fire blanket, eye wash, emergency shower, …

Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One or more of the following is true: Not Applicable
1. First aid kits are inadequate 1. First aid kits are adequate and stocked but
2. First response equipment is inadequate contents list missing
3. No stated process for access to First Aid kits 2. First response equipment is adequate, but
during all times of operation inspection log is missing
4. Inspection schedule is not followed 3. First Aid kits inspection tracking records
missing

Remote Verification Acceptable: YES

89 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 B4) Industrial Hygiene
Worker exposure to chemical, biological and physical agents is to be identified, evaluated, and controlled according to the hierarchy
of controls. If any potential hazards were identified, participants shall look for opportunities to eliminate and/or reduce the potential hazards. If
elimination or reduction of the hazards is not feasible, potential hazards are to be controlled through proper design, engineering and
administrative controls. When hazards cannot be adequately controlled by such means, workers are to be provided with and use
appropriate, well-maintained, personal protective equipment free of charge. Protective programs shall be ongoing and include
educational materials about the risks associated with these hazards.

90|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
B4.1 All required permits, licenses and testing reports for potential Industrial hygiene exposures are in place and a process is
implemented to ensure permits and licenses are up to date at all times
Conformance Requirements:
Site Observations Record Review
Not applicable 1) Process
a) A documented process is in place to ensure permits are renewed before current permits expire
2) Records
a) All required industrial hygiene permits and licenses are in place, available for review and valid.
b) Industrial hygiene testing reports are in place, available for review Industrial hygiene sampling records for the
past three years, including sampling performed by government agencies as part of a regulatory inspection are
available for review.

Additional assistance:
Site Observations Record Review
1) Process
a) A documented process e.g. A compliance calendar or reminders/tasks/calendar appointments via an e-mail
system.
1) Records
a) All industrial hygiene permits and licenses e.g.
i) Use permits
b) Industrial hygiene testing reports e.g.
c) Industrial hygiene monitoring logs

Rating:
Priority Major Minor Not Applicable
No health risk evaluation process has been One or more of the following is true: One of minimum requirement elements is missing No permits or license required. No testing
implemented 1) Required permits, licenses or testing reports or ineffective reports required.
missing
2) Two or more of minimum required elements
are missing or ineffective
Remote Verification Acceptable YES

91 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
B4.2 Adequate and effective process to be identify, evaluate, and control, according to the hierarchy of controls, worker exposure to
chemical, biological and physical agents .
Conformance Requirements
Site Observations Record Review
1) Adequate controls to reduce or eliminate worker exposure to chemical, 1) Process
biological and physical agents are in place and effective including: a) Adequate and effective risk assessment process to identify, evaluate, and control, according to the hierarchy of
a) Proper design (elimination and/or substitution) controls, worker exposure to chemical, biological and physical agents .
b) Engineering controls b) The risk assessment is updated when a Significant Change occurs
c) Administrative controls c) Risk assessment must include exposure to multiple chemicals
d) Adequate and effective PPE d) A health risk assessment with associated industrial hygiene sampling and testing, is completed when a new
2) During normal working hours, workplace is free from obvious odor, visible chemical, biological, or physical agent is introduced into the work environment, or when an existing process is
fume, dust, and other conditions leading to potential unhealthy feelings changed that may trigger an employee health risk.
2) Control program
a) Regular evaluation plan to verify the effectiveness to implemented controls and corrective actions if required.
The frequency should at least every 3 years unless a major change requires re-evaluation
3) Records
a) Medical surveillance records are available for review pertaining to respiratory evaluations to determine if
worker is being harmed from exposure to agents or determining hearing loss or any other medical concerns
related to specific job activities.

92 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Additional assistance:
Site Observations Record Review
1) Engineering controls = e.g. exhaust ventilation, enclosures, ... 1) Risk assessment
2) Administrative controls = limiting worker exposure time; job rotation, … a) Hierarchy of hazard control is a system used in industry to minimize or eliminate exposure to hazards. These
3) If obvious odor, visible fume, dust, and other conditions leading to potential are from most effective to least effective: 1. Elimination, 2. Substitution, 3. Engineering controls, 4. Administrative
unhealthy feelings exist, auditor should perform detail interview and controls, 5. PPE
inspections. b) Exposure to multiple chemicals is an exposure to multiple chemicals by a single route and exposure to multiple
chemicals by multiple routes. A route can inhalation, ingestion, skin exposure, …
c) Significant Change can be the introduction, elimination or change of 1 chemical
2) Records
a) Surveillance records are not limited to respiratory, but various exposures, such as skin contact, hearing loss,
radiation, ….
3) A PPE finding is noted in B1.3

Rating:
Priority Major Minor Not Applicable
One or more of the following is true: One or more of the following is true: One or more of the following is true: Not applicable
1. No health risk assessment or control 1. Potential hazards have been identified and 1. Potential hazards are controlled and
measures are in place risk assessment program is in place, but minimized but documentation and records are
2. Potential hazards are evident controls are inadequate. incomplete or does not follow the hierarchy of
2. Two or more of minimum requirement controls
elements are missing or ineffective 2. No consideration of combined exposure to
multiple chemicals
Remote Verification Acceptable: NO

93 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 B5) Physically Demanding Work
Worker exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting,
prolonged standing and highly repetitive or forceful assembly tasks is to be identified, evaluated and controlled.

94|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
B5.1 Worker exposure to the hazards of physically demanding work is identified, assessed, communicated and controlled effectively
Conformance Requirements:
Site Observations Record Review
1) Adequate controls to reduce or eliminate physical demanding work are in 1) Risk assessment
place and effective including: a) Adequate and effective risk assessment is in place to identify and assess the potential hazards of physical
a) Proper design demanding work.
b) Engineering controls b) The risk assessment is updated when a Significant Change occurs
c) Administrative controls 2) Control program
a) Adequate and effective documented program to control the identified potential hazards of physical demanding
work is place and follows the hierarchy of controls
b) Program encourages and respond to early reporting of discomfort.

Additional assistance:
Site Observations Record Review
1) Physical demanding work=e.g. Heavy or repetitive lifting, prolonged 1) Control program
standing, ... a) A review and trend analysis of past 3 years of injuries related to physical demands of job duties.
2) Engineering controls=e.g. Palletizers, lift tables, adjustable work platforms, b) If there are no changes to the facility or work set up, there is no need to re-assess (this “no-change” should be
… documented).
3) Administrative controls=e.g. limiting worker exposure time; job rotation, … c) Periodic ergonomic task analyses

Rating:
Priority Major Minor Not Applicable
1. No risk assessment or control measures are 1. Physically demanding work has been 1. Physically demanding work is controlled and No physically demanding work
in place AND high frequency of physically identified and risk assessment program is in minimized, AND physically demanding work
demanding work is evident place, but controls are inadequate monitoring program is adequate, but
documentation is incomplete
Remote Verification Acceptable: NO

95 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 B6) Machine Safeguarding
Production and other machinery shall be evaluated for safety hazards. Physical guards, interlocks and barriers are to be provided
and properly maintained where machinery presents an injury hazard to workers.

96|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
B6.1 All required permits, licenses and testing reports for machinery are in place and a process is implemented to ensure permits and
licenses are always up to date
Conformance Requirements:
Site Observations Record Review
Required postings are current and located in public view. 1) Process
a) A documented process is in place to ensure permits are renewed before current permits expire
2) Records
a) All required machine safety permits and licenses are in place, available for review and valid.
b) machine safety testing reports are in place, available for review

Additional assistance:
Site Observations Record Review
Some signage and information may be required to be posted in employee 1) Machines in scope are machine operated by workers to perform their main task. Machine which are part of building
common/break/cafeteria locations. or utilities (elevators, lifts, hoists, boilers, compressors) fall under B1.
2) Process
a) A documented process e.g. A compliance calendar or reminders/tasks/calendar appointments via an e-mail
system.
3) Records
a) All machine (safety) permits and licenses e.g.
i) Machine permits
b) Machine (safety) testing reports e.g.
i) Machine testing logs

Rating:
Priority Major Minor Not Applicable
Not applicable One or more of the following is true: One of minimum requirement elements is missing No permits or license required. No testing
1. Required permits, licenses or testing reports or ineffective, or a system element is not reports required.
missing adequately documented or is prohibited.
2. Two or more of minimum requirement
elements are missing or ineffective
Remote Verification Acceptable: YES

97 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
B6.2 An adequate and effective machine-safeguarding program is implemented, and workers operate machinery safely
Conformance Requirements:
Site Observations Record Review
1) Emergency stops 1) Machine risk assessment
a) All machines have adequate emergency stops a) Adequate and effective documented machine risk assessment process is in place including:
2) Safeguards b) Machine risk assessment program provides a method to identify machine safeguarding needs (pre-
a) All machines have adequate safeguards purchase/pre-installation hazard review of all machinery.)
3) Operation 2) Control program
a) All workers operate machine safely. a) Appropriate method is used to ensure that safeguarding is installed as needed to control the identified hazards,
b) Regular inspection and preventive maintenance of machine and its safeguards and emergency stops.
3) Work instructions
a) Work instructions (if necessary or required) are available in a language understood by the worker at machine
(or within proximity).
b) Safe machine operation documentation is in place and available.

Additional assistance:
Site Observations Record Review
Machine safeguards=e.g. machine pinch points, points-of-operation, rotating 1) Machine = any equipment with at least one moving part. Machines in scope are machine operated by workers to
shafts, flywheels, chain drives, motor-driven movement, … perform their main task. Machine which are part of building or utilities (elevators, lifts, hoists, boilers, compressors)
fall under B1.
2) Control program
a) Records demonstrating regular inspection and preventive maintenance of machine are available for review
(3years)

Rating:
Priority Major Minor Not Applicable
1. Worker operates machine unsafely with 1. Worker operates machine unsafely without 1. Workers operate machines safely, but work 1. No physical machine hazards
immediate risk of life or limb immediate risk of life or limb instructions are incomplete
2. Machine safeguarding program is in place but
incomplete
Remote Verification Acceptable: YES, if minor, otherwise NO.

98 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 B7) Food, Sanitation and Housing
Workers are to be provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and
eating facilities. Worker dormitories provided by the Auditee or a labor agent are to be maintained clean and safe, and provided with
appropriate emergency egress, hot water for bathing and showering, and adequate lighting, heat and ventilation, individually secured
accommodations for storing personal and valuable items, and reasonable personal space along with reasonable entry and exit
privileges.

99|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
B7.1 All required health & safety licenses, permits, registrations and certificates related to food, sanitation and housing are in place
and an adequate and effective process is established to ensure permits and licenses are up to date at all times
Conformance Requirements:
Site Observations Record Review
Valid hygiene permit is placed on site (if applicable) 1) A documented process is in place to ensure permits are renewed before current permits expire
2) Records
a) All required food, sanitation and housing permits and licenses are in place, available for review.
b) Food, sanitation and housing testing reports are in place, available for review.

Additional assistance:
Site Observations Record Review
1) Process
a) A documented process e.g. a compliance calendar or reminders/tasks/calendar appointments via an e-mail system.
2) Records
a) Rented apartments must be permitted by the local government
b) food, sanitation and housing permits and licenses e.g.
i) Canteen/kitchen workers have valid health certificates.
c) food, sanitation and housing testing reports e.g.
i) Drinking water
ii) Food worker health tests
iii) Food sample testing
d) If local regulations require facility health inspections or other tests or certificates, these are available and valid.
3) Drinking water
a) Water must be tested for those contaminants assessed to be at risk for the local region and operations. Drinking water testing is not
required if local water utility company can attest water meets World Health Organization (WHO) Guidelines for Drinking-water Quality
or equivalent standard
If drinking water is not a separate system or no additional contamination can take place (e.g. filters, …) then report only in B1.1

100 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: 1. One of minimum requirement elements is All of the following is true:
1. Required permits, licenses or testing reports missing or ineffective, or a system element is 1. No permits or license required
are missing not adequately documented or is prohibited 2. No testing reports required
2. Canteen/kitchen worker certificates are 3. There is no dormitory,
missing or expired restaurant/canteen at the facility.
3. Two or more of minimum requirement
elements are missing or ineffective

Remote Verification Acceptable: YES

101
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
B7.2 Dormitories, bathrooms, employee spaces are clean, safe and well-maintained and meet international housing standards
Conformance Requirements:
Site Observations Record Review
1) Environment 1) Procedures
a) Dormitory and sanitary facilities (common areas, hallways, rest a) Adequate and effective cleaning and sanitation program is in place.
rooms, …) are clean and properly maintained. b) Adequate and effective pest control program is in place
b) Clear, well-lit stairwells to allow for safe exit from dormitories c) Adequate and effective preventive maintenance program (including emergency response supporting facilities)
c) Building is heated in the winter (if applicable). is in place
d) Windows provide light and ventilation. d) For rented apartments, performs a risk assessment and updates if there is a Significant Change, on-site
e) Adequate lighting inspections and emergency procedures
f) Safe and sufficient electricity sockets are provided. 2) Records
g) Sufficient space is available for each worker a) Sanitation program tracking records are available for review and up to date.
h) Individually secured storage accommodations b) Pest control log is available for review and up to date.
2) Structure and lay-out c) Preventive maintenance program logs available for review and up to date.
a) All facilities are separated by gender and adequate in number.
b) Lodging and cooking facilities are separate
c) Adequate domestic waste disposal facilities
d) Adequate pest control
3) Emergency response
a) Adequate fire and heat detection, alarm and notification and fire
suppression systems are in place
b) Adequate number of exit routes from each floor.
c) Exit route doors accessible, well-marked and unlocked from the inside
d) Adequate number of first kits are available

102 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Additional assistance:
Site Observations Record Review
1) Adequate lighting = lighting is adequate for reading, writing and other off-
work activities
2) individually secured storage accommodations = storage for personal and
valuable items protected from unauthorized access and accessible to the
workers at any time
3) Exit route doors unlocked from the inside = doors may be locked from the
outside only if panic hardware, such as crash bars, are used
4) The dormitory requirements shall apply regardless of the nature of contract
/ location / building (for example if rooms are rented by the facility in nearby
residential areas for housing employees, these standards will still apply

Rating:
Priority Major Minor Not Applicable
1. Dormitory/rented apartments is/are unsafe One or more of the following is true: One or more of the following is true: 1. No worker housing.
with immediate risk of loss of facility, life or 1. Dormitory and sanitary facilities are unclean 1. Dormitory and sanitary facility are safe, clean
limb or do not minimum requirements (except and adequate but procedures or records are
documentation) missing or incomplete.
2. Rented apartments are unsafe 2. Rented apartments are safe, clean and
3. Rented apartments did not have a risk adequate but on-site inspections are
assessment or inspection No emergency irregular
drills in rented apartments
Remote Verification Acceptable: NO

103
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
B7.3 Facility Bathrooms, employee spaces, cafeterias, food areas are safe, are clean, well maintained, and well managed
Conformance Requirements:
Site Observations Record Review
1) Environment 1. Procedures
a) Bathrooms, employee spaces, cafeterias, food areas are safe, clean and well maintained. 1) Safe food handling procedures and hygiene standards (in refrigeration,
b) Exits must be adequate for the number of workers served. storage, and preparation areas) are in place and followed.
c) Canteens are provided with adequate hand washing facilities. 2) Adequate and effective cleaning and sanitation program is in place.
d) Adequate pest control 3) Adequate and effective pest control program is in place
2) Food workers 4) Adequate and effective preventive maintenance program (including
a) Food service workers wear masks, hairnets and gloves as necessary to prevent food contamination. emergency response supporting facilities) is in place
3) Emergency response 5) Records
a) Adequate fire and heat detection, alarm and notification and fire suppression systems are in place a) Regular monitoring and reporting of safe food handling
b) Adequate number of exit routes from each floor. procedures/hygiene
c) Exit route doors accessible, well-marked and unlocked from the inside b) Sanitation program tracking records are available for review and
d) Maximum occupancy number is posted on site up to date.
e) Adequate number of first kits are available c) Pest control log is available for review and up to date.
4) Food storage: d) Preventive maintenance program logs available for review and up
a) Food storage and preparation areas are clean to date.
b) Food is stored properly (not on the floor; refrigerated if necessary)
c) Raw and cooked food stored separately, food kept covered, ...
d) Food is used or disposed of before the marked expiration date

104 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Additional assistance:
Site Observations Record Review

Rating:
Priority Major Minor Not Applicable
1. Canteen and kitchen are unsafe with One or more of the following is true: 1. One of minimum requirement elements is Not applicable
immediate risk of loss of facility, life or 1. Canteen and kitchen are unclean missing or ineffective, or a system element is
serious injury 2. Canteen and kitchen do not meet minimum not adequately documented or is prohibited
requirements on canteen/cafeteria standards
3. Two or more of minimum requirement
elements are missing or ineffective
Remote Verification Acceptable: NO

105
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 B8) Health and Safety Communication
Participant shall provide workers with appropriate workplace health and safety information and training in the language of the
worker or in a language the worker can understand for all identified workplace hazards that workers are exposed to, including but
not limited to mechanical, electrical, chemical, fire, and physical hazards. Health and safety related information shall be clearly
posted in the facility or placed in a location identifiable and accessible by workers. Training is provided to all workers prior to the
beginning of work and regularly thereafter. Workers shall be encouraged to raise any health and safety concerns without retaliation.

106
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
B8.1 Workers are provided with appropriate clearly posted workplace health and safety information and training in the language of the
worker or in a language the worker can understand for all identified workplace hazards that workers are exposed to. Workers shall be
encouraged to raise any health and safety concerns without retaliation
Conformance Requirements:
Site Observations Record Review
1) Health and Safety communication clearly posted in 1) Language
the facility or placed in a location identifiable and a) All communications and training must be in a language understood by the worker
accessible by workers 2) Training:
2) Appropriate signs, placards and labels identifying a) Adequate and effective training program is in place following good training program practice
hazards (chemical, physical, biological, vehicular, …) b) Training program has minimum requirements (mechanical, electrical, chemical, fire, and physical hazards) training and training
3) A mechanism to raise safety concerns is clearly identified in the training needs assessment but must include
visible i) The correct use of appropriate PPE
ii) Types of potential emergencies that may occur at their work location and what to do during an emergency, including Internal and
external muster points.
iii) Machine safety and the use of safeguards and emergency stops.
iv) Reporting injuries and illnesses
v) Hazardous atmospheres and confined space work procedures prior to entry of confined spaces
vi) Lock out-tag out procedures
vii) Specific training for ERT, first responders and medical professionals
c) Training is provided to all workers prior to the beginning of work and regularly thereafter as per the training program.
d) Workers responsible for storage, clean up or disposal of chemical releases should receive specialized training.
e) Occupational health professionals and first responders are trained by external agencies or trained and certified by internal qualified
occupational health professionals such as medical doctor where permitted by local law
3) Communication:
a) Adequate and effective communication program to workers/employees is in place for all identified
b) Potential workplace hazards that workers are exposed to clearly posted in the facility or placed in a location identifiable and accessible
by workers
c) Hazard communication procedure: all hazards present at the site and action promoting of an H&S workplace.
d) Internal and external muster points are communicated to all employees and visitors
4) Health and safety concern notification
a) Adequate and effective program to receive, review and respond to any health and safety concerns reported. (e.g. incentive systems,
….).
b) Workers shall be encouraged to raise any health and safety concerns without retalitation
5) Evaluation
a) The training, communication and safety concern notification programs must be evaluated on a regular basis not exceeding 3 years or
sooner if there is a major change
6) Records
a) Training records include a verification of training effectiveness
b) Safety concern logs, evaluation records and action plans

107
c) Communication records, logs and materials

|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 d) Training, communication and safety concern notification evaluation reports and corrective action if required
e) Educational materials (e.g. safe work instruction, operating instruction, …) about the risks associated with the hazards for their
positions are provided to workers to ensure safe execution of the function. Examples of controls include personal protective equipment
(safety glasses, gloves, and ear plugs), operating procedures (lock-out/tag-out, chemical mixing), and engineering controls
(ventilation, point of operation machine guarding, building sprinkler systems).
f) Girevance records show health and safety concerns, their response and no retaliation

Additional assistance:

Site Observations Record Review

1) Good training program practice
a) H&S training needs analysis is conducted and is documented
b) A training matrix has been developed following the training needs analysis (including but not limited to mechanical, electrical,
chemical, fire, and physical hazards)
c) A training plan is in place, building on the training matrix
d) A training program with materials and training records is in place, adequate and up to date.
e) Training program is up to date and maintained through a compliance calendar, work-order systems, and computer-based e-
mail/calendar system.
f) Refresher training schedules are established and implemented as per schedule
Communication:
g) Updates should be made whenever new operations, chemicals, machines or process are added in the facility or change significantly
Records
Verification of training effectiveness=e.g. demonstrate that workers have understood training and aims of training are achieved
(through a post training test, or worker interviews on the training)
2) ERT member training must be reported in B2.6

108 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
1. No training and/or 1. Training and communications program in place but major hazards or 1. Training and communications Not Applicable
communication program in program components missing program in place but
place 2. No training provided on one or more of the minimum elements: communications are not updated in
chemicals, hazardous substances (including waste), PPE, emergency accordance with developed schedule
evacuation, machinery safety, reporting injuries or training records/verification
3. Two or more of minimum requirement elements are missing or incomplete
ineffective
4. No system in place to raise safety concerns
5. First responder training does not meet minimum requirements in
content or number
Remote Verification Acceptable: NO

109
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
4. C. ENVIRONMENT
Participants recognize that environmental responsibility is integral to producing world class products. In manufacturing operations,
adverse effects on the community, environment and natural resources are to be minimized while safeguarding the health and safety of
the public. Recognized management systems such as ISO 14001 and the Eco Management and Audit System (EMAS) were used as
references in preparing the Code and may be a useful source of additional information.

GENERAL NOTES
• A risk assessment must be updated if there is a Significant Change.
• For facilities with significant EHS risks an EHS expert Auditor will be added to the audit team for an expert review of these policies, programs,
and performance.
• Where monitoring, testing, audits or other assessments are required and law, licenses or permits are silent on the frequency, then the
frequency must not exceed three years unless there are significant changes to the process, facility or product use

110
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 C1) Environmental Permits and Reporting
All required environmental permits (e.g. discharge monitoring), approvals and registrations are to be obtained, maintained and kept
current and their operational and reporting requirements are to be followed.

111
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
C1.1 The facility has obtained all required environmental permits, approvals, licenses and registrations
Conformance Requirements:
Site Observations Record Review
1) Any unidentified impacts to: 1) Process
a) Air emissions a) A documented process is in place to ensure permits, approvals, registrations or licenses are renewed before current permits,
b) Wastewater discharge approvals, registrations or licenses expire
c) Storm water exposure 2) Records
d) Hazardous materials storage and use a) All required environmental permits, approvals, registrations and licenses are in place, available for review and valid.
e) Generation of waste (solid and hazardous)

Additional assistance:
Site Observations Record Review
1) Process
a) A documented process e.g. a compliance calendar or reminders/tasks/calendar appointments via an e-mail system.
b) Any alteration that may change the status of registration and permitted hazardous-waste generation to the appropriate local and
national regulatory agencies
2) Records
a) Environmental permits, approvals registrations and licenses e.g.
i) Operating permit
ii) Air emissions
iii) Wastewater discharge
iv) Storm water exposure
v) Hazardous materials storage and use
vi) Generation of waste (solid and hazardous)
b) Current copies of all hazardous waste vendor licenses and/or approvals are on file.

112 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
Not applicable One or more of the following is true: 1. One of minimum requirement elements is 1. No permits, approvals, registrations or
1. Required permits, licenses or testing reports missing or ineffective, or a system element is license required.
missing not adequately documented or is prohibited
2. Two or more of minimum requirement
elements are missing or ineffective

Remote Verification Acceptable: YES

113
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
C1.2 Reporting to environmental authorities as required by law is performed timely.
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Process
a) A documented process is in place to ensure reports are submitted before or on due date is in place
2) Records
a) Environmental testing reports are in place, available for review and meeting the conditions of permits or licenses

Additional assistance:
Site Observations Record Review
1) Process
a) A documented process e.g. a compliance calendar or reminders/tasks/calendar appointments via an e-mail
system.
2) Records
a) Environmental testing reports e.g.
i) Air emissions
ii) Water emissions
iii) Waste
iv) Hazardous waste

Rating:
Priority Major Minor Not Applicable
1. Mandatory government reporting is late for 1. Required reports missing, incomplete AND no One or more of the following is true: 1. No environmental reporting required
more than 3 months process in place to ensure legally required 1. Required reports submitted but no process in
reports are submitted in a timely manner place to ensure legally required reports are
submitted in a timely manner
2. Required reports submitted in a timely
manner but incomplete

Remote Verification Acceptable: YES

114 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
C2) Pollution Prevention and Resource Reduction
Emissions and discharges of pollutants and generation of waste are to be minimized or eliminated at the source or by practices
such as adding pollution control equipment; modifying production, maintenance and facility processes; or by other means. The use
of natural resources, including water fossil fuels, minerals and virgin forest products is to be conserved by practices such as
modifying production, maintenance and facility processes, materials substitution, re-use, conservation, recycling or other means.

115
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
C2.1 Adequate and effective programs, including objectives and targets, to identify, manage, minimize or eliminate at the source
emissions and discharges of pollutants and generation of waste and conserve the use of natural resources
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Policy
a) Adequate and effective programs to identify, manage, minimize or eliminate at the source emissions and discharges of pollutants, generation
of waste and conserve the use of natural resources including:
i) Materiality assessment: identify significant environmental aspects and establish programs for monitoring and control of these aspects.
ii) Clear annual objectives and targets are set for each identified material emission source, waste including hazardous waste and natural
resource used demonstrating annual progress not entailing excessive cost
(1) Reduce resource consumption
(2) Reduce waste and pollution generation
(3) Capture or reuse materials that would otherwise enter waste streams
2) Records
a) Materiality assessment (updated when changes in machinery, process or materials used or facility)
b) Data for each material emission and discharge of pollutants, waste and natural resource

Additional assistance:
Site Observations Record Review
1) Elimination or minimization e.g. by practices such as adding pollution control equipment; modifying production, maintenance and facility processes;
or by other means.
2) Natural resources = e.g. Water fossil fuels, minerals and virgin forest products
3) Conservation of the use of natural resources e.g. By practices such as modifying production, maintenance and facility processes, materials
substitution, re-use, conservation, recycling or other means.
4) Reduction programs are implemented where they don't present increased worker harm or excessive cost
5) The goal of this provision is to confirm that a facility has done a materiality assessment and understands its materials resource use and
environmental impacts and has set clear annual objectives to reduce this impact.
6) The implementation of the programs to meet these reduction objectives are covered in the individual environmental media provisions C3, C4, C5, C7
and C8.
Rating:
Priority Major Minor Not Applicable
1. Reduction programs cause potential One or more of the following is true: One or more of the following is true: Not Applicable
worker harm 1. No assessment of resource use and waste generation has 1. Assessment of resource use and waste generation is incomplete
been completed 2. Selection processes for all new hazardous chemicals is incomplete
2. No selection processes for all new hazardous chemicals 3. Reduction objectives set but incomplete for a material component
3. No reduction objectives set 4. One of minimum requirement elements are missing or ineffective
4. Two or more of minimum requirement elements are
missing or ineffective

116 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 Remote Verification Acceptable: YES

C3) Hazardous Substances

Chemical, waste and other materials posing a hazard to humans or to the environment are to be identified, labelled and managed to
ensure their safe handling, movement, storage, use, recycling or reuse and disposal.

117
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
C3.1 Hazardous substances including wastes are properly categorized, labeled, handled, stored and transported and disposed using
government-approved and/or licensed vendors.
Conformance Requirements:
Site Observations Record Review
1) Management 1) Policy
a) Hazardous substances are adequately and effectively a) Adequate and effective procedures are in place for
i) Categorized i) Reception
ii) Handled ii) Storage
iii) Stored iii) Dispensing
iv) Moved within a single facility/ multiple facility. iv) Use
2) Control b) Adequate and effective process to track, review, and approve the use of all hazardous chemicals and shall obtain
a) Access to hazardous substances is controlled approvals for all new purchases of hazardous chemicals prior to use.
b) Potential employee exposure methods are adequate and effective such c) Selection processes for all new hazardous chemicals include a thorough evaluation of less hazardous or non-
as hazardous alternatives.
i) Segregation 2) Hazard information (Environmental)
ii) Secondary containment a) Hazardous material information [labels and safety data sheet (SDS formally MSDS)] or characterization in the
iii) Ventilation case of hazardous waste) is available at the points of use and storage in a language understood by the worker.
iv) Fire protection 3) Records
v) Appropriate storage cabinets a) Accurate chemical inventory records are maintained and available for review.
3) Hazard information b) Inspection records of hazardous substances and their points of storage and use are maintained and available
a) Hazard signage and information [labels and safety data sheet (SDS for review.
formally MSDS) or characterization in the case of hazardous waste) c) Copies of hazardous substances inventory, manifests and shipping papers are maintained and available for
review.
d) Documents only vendors approved and/or licensed by the local regulatory authorities for transporting are used.

118 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Additional assistance:
Site Observations Record Review
1) Engineering and administrative systems intended to improve resource 1) Records
efficiency are in good repair or operating at high capacity. a) Copies of hazardous substances inventory, manifests and receiving shipping papers e.g. may be related to:
2) Engineering and administrative systems for improved resource efficiency i) Air emissions;
adhere to the hierarchy of resource efficiency when feasible, showing ii) Process wastewater storage;
preference (in order) for the following functions: iii) Hazardous materials storage and use; and
a) Prevention: unnecessary consumptive processes are eliminated iv) Hazardous waste storage
b) Minimization: Process efficiency is improved 2) Hazard information (Health & Safety) finding should be noted in B8
c) Substitution: Using a more environmentally benign or renewable
resource
d) Reuse, recycling, recovery: In that order, in order to maximize the
benefit of resource consumption

3) Hazard information (Health & Safety) finding should be noted in B8

Rating:
Priority Major Minor Not Applicable
1. Hazardous substances (including wastes) are 1. Two or more of minimum requirement 1. One of minimum requirement elements is 1. No hazardous substances (including wastes)
used, handled or stored of in a manner that elements are missing or ineffective missing or ineffective, or a system element is used or stored on site.
could result in imminent loss of facility, life or not adequately documented or is prohibited
cause severe bodily damage.

Remote Verification Acceptable: YES

119|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
C3.2 Hazardous waste is safely disposed of including a disposal Supplier(s) assessment
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Policy
a) Adequate and effective procedures are in place for the safe return and disposal of hazardous waste.
2) Reduction program
a) An adequate and effective reduction program with
i) Annual objectives
ii) Regular objective tracking
iii) Progress monitoring
iv) Adjustments made if off track
3) Hazard information (Environmental)
a) Hazardous material information [labels and safety data sheet (SDS formally MSDS)] or characterization in the case of hazardous
waste) is available at the points of use and storage in a language understood by the worker.
4) Vendor assessment
a) A periodic assessment and corrective action plan process to evaluate whether the vendor (hazardous waste handler AND transporter)
is complying with contract terms and conditions
b) Assessments should occur at least every 3 years or when there is a significant change
c) The assessment must occur before a new vendor (hazardous waste handler AND transporter) is selected
5) Records
a) Documents that only vendors approved and/or licensed by the local regulatory authorities for transporting and disposing of hazardous
waste are used
b) Assessments visit minutes or Audit reports, with possible areas for improvement are available for review.
c) Copies of hazardous waste shipping papers
d) Annual reduction targets, progress monitoring and corrective actions plans if applicable

120 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Additional assistance:

Site Observations Record Review

1) Assessment
a) If corrective or improvement actions are identified, then implementation is monitored, and actions are completed or on track.
b) If corrective actions are off track, then additional actions are identified to ensure corrective actions are completed by due date.
2) Objective setting finding is listed in C2.1
3) Auditor guidance: Reporting on this question will include the detail of the current targets and current progress against the targets

Rating:
Priority Major Minor Not Applicable
1. Environmental emissions are evident that One or more of the following is true: 1. One of minimum requirement elements is 1. No hazardous chemical waste generated or
could cause imminent negative impact on the 1. No control programs in place and there is a missing or ineffective, or a system element is stored on site.
community (toxic air and water emissions, risk of environmental emissions not adequately documented
untreated wastewater release, chemicals 2. No baseline to reduce environmental impacts
spill on hazardous substances released 3. No hazardous waste vendor assessment
outside the facility, ...) 4. Two or more of minimum requirement
elements are missing or ineffective
Remote Verification Acceptable: YES

121
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 C4) Solid Waste
Participant shall implement a systematic approach to identify, manage, reduce and responsibly dispose of or recycle solid waste
(non-hazardous).

122
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
C4.1 Solid waste is managed and responsibly disposed of
Conformance Requirements:
Site Observations Record Review
1) Management 1) Policy
a) Waste is adequately and effectively a) Adequate and effective procedures are in place for
i) Categorized i) Storage
ii) Handled ii) Handling
iii) Stored iii) Transportation
iv) Moved within a single facility/ multiple facility. iv) Disposal.
2) Facilities Control b) Adequate and effective process to track, review, and approve the disposal of all waste
a) Access to waste is controlled 2) Reduction program
b) Potential employee exposure methods are adequate and effective such a) An adequate and effective reduction program with
as i) Annual objectives
i) Segregation ii) Regular objective tracking
ii) Secondary containment iii) Progress monitoring
iii) Ventilation iv) Adjustments made if off track
iv) Fire protection 3) Hazard information (Environmental)
3) Hazard information a) Material information [labels and safety data sheet (SDS formally MSDS)] or characterization in the case of waste)
a) Hazard signage and information and waste characterization and is available at the points of use and storage in a language understood by the worker.
response information 4) Records
4) Reduction programs are visible within the facility. a) Accurate waste inventory records are maintained and available for review.
b) Inspection records of waste and their points of storage are maintained and available for review on site.
c) Copies of waste manifests and shipping papers are maintained and available for review.
d) Documents only vendors approved and/or licensed by the local regulatory authorities for transporting are used.
e) Annual reduction targets, progress monitoring and corrective actions plans if applicable

123 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Additional assistance:
Site Observations Record Review
1) Engineering and administrative systems intended to improve resource 1) Objective setting finding is listed in C2.1
efficiency are in good repair or operating at high capacity. 2) Hazard information (Health & Safety) finding should be noted in B8
2) Engineering and administrative systems for improved resource efficiency 3) Auditor guidance: Reporting on this question will include the detail of the current targets and current progress against
adhere to the hierarchy of resource efficiency when feasible, showing the targets
preference (in order) for the following functions:
a) Prevention: unnecessary consumptive processes are eliminated
b) Minimization: Process efficiency is improved
c) Substitution: Using a more environmentally benign or renewable
resource
d) Reuse, recycling, recovery: In that order, in order to maximize the
benefit of resource consumption

Rating:
Priority Major Minor Not Applicable
1. Environmental emissions are evident that One or more of the following is true: 1. One of minimum requirement elements is 1. No solid waste generated or stored on site.
could cause imminent negative impact on the 1. No control programs in place and there is a missing or ineffective, or a system element is
community (toxic air and water emissions, risk of environmental emissions not adequately documented
untreated wastewater release, chemicals 2. No baseline to reduce environmental impacts
spill on hazardous substances released 3. Two or more of minimum requirement
outside the facility, ...) elements are missing or ineffective
Remote Verification Acceptable: YES

124 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 C5) Air Emissions
Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting substances and combustion by-
products generated from operations are to be characterized, routinely monitored, controlled and treated as required prior to
discharge. Ozone depleting substances are to be effectively managed in accordance to the Montreal Protocol and applicable regulations.
Participant shall conduct routine monitoring of the performance of its air emission control systems.

125
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
C5.1 Air emissions are routinely monitored, and air emission control systems are routinely monitored for performance.
Conformance Requirements:
Site Observations Record Review
1) Equipment 1) Policy
a) Equipment for air emission treatment is well maintained and a) Adequate and effective procedures are in place for air emissions
appropriate and identified i) Treatment
2) Treatment ii) Discharge
a) Air emission are treated prior to discharge in accordance with permit b) Adequate and effective process to track, review, and approve the discharge of all air emissions
requirement c) Emergency response actions are defined in case the on-site air emissions treatment system malfunctions
3) Reduction programs are visible within the facility. d) Ozone depleting substances are managed in accordance to the Montreal Protocol and applicable regulations.
4) Ozone depleting substances are clearly labeled 2) Reduction program
a) An adequate and effective reduction program with
i) Annual objectives
ii) Regular objective tracking
iii) Progress monitoring
iv) Adjustments made if off track
3) Equipment
a) Appropriate process air emission treatment systems are installed and maintained that minimize the pollutant
contribution of each of its facilities include:
i) A routine preventive maintenance program
ii) System efficiency monitoring program
iii) A program to evaluate the integrity of existing process air emission systems
4) Personnel:
a) A specific individual or individuals within the facility organization who will be responsible for all aspects of
process air emission treatment
5) Records
a) Inspection records of air emission and their points of discharge are maintained and available for review.
b) Testing and reporting records are maintained and available for review
c) Revise the inventory after any changes to the production or process that are likely to affect air emissions
d) List of air emissions and Ozone Depleting Substances is up to date and accurate

126 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Additional assistance:
Site Observations Record Review
1) Engineering and administrative systems intended to improve resource 1) Equipment:
efficiency are in good repair or operating at high capacity. a) A program to evaluate the integrity of existing process air emission treatment systems:
2) Engineering and administrative systems for improved resource efficiency i) Regularly test of the air emission system
adhere to the hierarchy of resource efficiency when feasible, showing ii) Correct any identified deficiencies immediately
preference (in order) for the following functions: 2) Personnel
a) Prevention: unnecessary consumptive processes are eliminated a) Wastewater treatment responsibilities include:
b) Minimization: Process efficiency is improved i) Maintenance
c) Substitution: Using a more environmentally benign or renewable ii) Inspection of air emission treatment equipment
resource iii) Monitoring of air emissions
d) Reuse, recycling, recovery: In that order, in order to maximize the iv) Responding to emergencies
benefit of resource consumption 3) Ozone depleting substances are substances or materials containing Chlorofluorocarbons (CFCs),
Hydrochlorofluorocarbons (HCFCs), Hydrobromoflurocarbons (HBFCs), Halons, Methyl bromide, Carbon tetrachloride
and Methyl chloroform. They can mostly be found in refrigerants, foam blowing agents, components in electrical
equipment, industrial solvents, solvents for cleaning (including dry cleaning, Aerosol spray propellants, fumigants
4) Auditor guidance: Reporting on this question will include the detail of the current targets and current progress against
the targets

Rating:
Priority Major Minor Not Applicable
1. Environmental emissions are evident that One or more of the following is true: 1. One of minimum requirement elements is 1. No air emissions - site does not have
could cause imminent negative impact on the 1. Air emissions are not complying with missing or ineffective requirements for air emissions.
community (toxic air and water emissions, discharge requirement
untreated wastewater release, chemicals spill 2. Workers responsible for operating and
on hazardous substances released outside the maintaining air emission treatment systems
facility, ...) are untrained
3. Monitoring is not carried out on a regular
basis
4. No baseline to reduce environmental impacts
5. Two or more of minimum requirement
elements are missing or ineffective

Remote Verification Acceptable: YES

127 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
C5.2 Environmental noise levels are within regulatory limits
Conformance Requirements:
Site Observations Record Review
1) No excessive boundary noise 1) Policy
a) Adequate and effective procedures are in place for environmental noise control including boundary noise sources are
i) Identified
ii) Evaluated
iii) Routinely monitored
iv) Controlled
b) Adequate and effective process to track and review environmental noise
2) Equipment
a) Appropriate boundary-noise-control devices are installed and maintained to control boundary noise levels include:
i) A routine preventive maintenance program
ii) System efficiency monitoring program
iii) A program to evaluate the integrity of existing boundary-noise-control devices
3) Personnel:
a) A specific individual or individuals within the facility organization who will be responsible for all aspects of environmental noise control
4) Records
a) Testing and reporting records are maintained and available for review

Additional assistance:
Site Observations Record Review
1) Boundary noise levels are evaluated per the permit conditions, upon changes to “Receiving Land Use Category” in the neighborhood of the facility, or if
there are any community noise complaints and boundary noise–level criteria are set accordingly.
2) Personnel
a) Environmental noise control responsibilities include:
i) Maintenance
ii) Inspection of boundary-noise-control devices
iii) Monitoring of boundary noise
iv) Responding to emergencies

128|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
Not Applicable 1. Two or more of minimum requirement 1. One of minimum requirement elements is 1. Site does not have requirements on
elements are missing or ineffective missing or ineffective, or a system element is environmental noise
not adequately documented or is prohibited

Remote Verification Acceptable: YES

129|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 C6) Materials Restrictions
Participants are to adhere to all applicable laws, regulations and customer requirements regarding prohibition or restriction of
specific substances in products and manufacturing, including labeling for recycling and disposal.

130
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
C6.1 Adequate and effective program is in place for Materials Restrictions as a formal part of the procurement and manufacturing
processes
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Corporate level implementation
a) Documented corporate policy
b) Documented corporate process
c) Assigned responsibility
d) Proof of implementation
2) Facility level (in case no corporate level implementation)
a) Policy
i) Adequate and effective procedures to measure and/or document the chemical composition of products
including:
(1) A documented review process for comparing customer requirements to own specifications
(2) A documented process to ensure materials, packaging and components procured are in conformance
with customer requirements
(3) Documented requirements for conformance with the Material Restrictions required to its material
/parts Suppliers
ii) Statements and/or certificates of conformance and analytical data to its customers upon request ae
provided
b) Records
i) Chemical composition of products is on record
ii) specifications, statements and/or certificates of conformance from its Suppliers
iii) Monitoring & reporting records from the past 3 years are available and ready for review

Additional assistance:
Site Observations Record Review
1) Policy
a) A documented process to ensure materials, packaging and components procured are in conformance with
customer requirements
i) Regular audits and assessments of the procedures are performed to verify conformance.
ii) A formal process is in place to address discovery of non-compliant materials or components and corrective
actions are tracked, implemented.
iii) Additional actions taken to ensure completion at due date if corrective actions are not on track.
iv) Analytical data from material/parts Suppliers is requested/required

131 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
1. No program is in place AND product has been One or more of the following is true: 1. One of minimum requirement elements is 1. Site is not subject to any requirements or
subject to regulatory action 1. No program is in place missing or ineffective, or a system element is customer demands on this topic.
2. Two or more of minimum requirement not adequately documented or is prohibited
elements are missing or ineffective
3. The responsibility could be shared corporate
and facility then complete the relevant section
1 and/or 2
a. If implementation is done at
corporate level then verify 1), if not
complete then “Major”
b. if implementation at facility level
then verify 2)
c. If implementation at both levels
then verify 1) and 2) then the highest
of both rating apply
Remote Verification Acceptable: YES

132|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 C7) Water Management
Participant shall implement a water management program that documents, characterizes, and monitors water sources, use and
discharge; seeks opportunities to conserve water; and controls channels of contamination. All wastewater is to be characterized,
monitored, controlled, and treated as required prior to discharge or disposal. Participant shall conduct routine monitoring of the
performance of its wastewater treatment and containment systems to ensure optimal performance and regulatory compliance.

133
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
C7.1 Adequate and effective procedures are in place to document, characterize, and monitor water sources, water discharge and control
channels of contamination
Conformance Requirements:
Site Observations Record Review
1) Water withdrawal 1) Water withdrawal
a) Water withdrawal and discharge points don't a) The source of water is clear
appear to heavily impact local waterbodies (e.g. b) A baseline of water use and adequate and effective annual reduction plan is implemented with objectives and corrective action plans
strongly colored discharge, acrid smell, floating if the implementation is off track.
debris). c) Annual reduction program should not harm workers or entail excessive cost.
2) Water discharge 2) Water discharge
a) Equipment a) Policy
i) Equipment such as tanks, piping, and i) Adequate and effective procedures are in place for wastewater
storage vessels are compatible with the (1) Storage
waste materials being stored and (2) Treatment
transported. (3) Discharge
b) Treatment b) Adequate and effective process to track, review, and approve the discharge of all wastewater
i) Industrial and/or sanitary wastewater is c) Emergency response actions are defined in case the on-site wastewater treatment system exceeds its capacity or if it malfunctions
treated in accordance with permit d) Hazard information
requirements. i) Wastewater characterization and response information is available at the points of use and storage in a language understood by
ii) Wastewater treatment system is in the worker.
operation and appears based on visual e) Equipment
inspection to be operating effectively. i) Appropriate process wastewater treatment systems are installed and maintained that minimize the pollutant contribution of each
c) Discharge of its facilities include:
i) Wastewater is discharged to a municipal (1) A routine preventive maintenance program
treatment system or to surface water (2) System efficiency monitoring program
3) Reduction programs are visible within the facility. (3) A program to evaluate the integrity of existing process wastewater collection systems
4) Control of internal water channel contamination 3) Control of internal water channel contamination
a) Internal water channels a) Adequate and effective procedures to control internal water channel contamination including:
i) Water channels look free of contamination b) Potential contamination sources to water channels are identified
ii) Water channels are protected from c) Adequate and effective emergency response plan to control water channel contamination
contamination (e.g. Absence of pools of d) Appropriate emergency response equipment inspection and maintenance process
standing water and grease/oil slicks near e) Investigation of past spills/water channel contamination and corrective/preventive action plan
storm drains.) 4) Personnel
b) Emergency response a) At least one responsible for all aspects of process wastewater discharge including treatment, water channel contamination prevention
i) Appropriate emergency response and water-related emergency response and reporting activities
equipment / materials are in place to 2) Records
respond to a possible water channel a) Identified water channel contamination sources
contamination b) Description of spills/water channel contamination for past 3 years
c) Preventive/corrective action plan for past spills/contamination

134
d) Additional actions taken to ensure completion at due date if corrective actions are not on track.

|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 e) Accurate wastewater inventory records are maintained and available for review.
f) Inspection records of wastewater and their points of storage are maintained and available for review.
g) Copies of wastewater manifests and shipping/discharge papers are maintained and available for review.
h) Documents only vendors approved and/or licensed by the local regulatory authorities for transporting are used.
a) Annual reduction targets, progress monitoring and corrective actions plans if applicable

Additional assistance:
Site Observations Record Review
1) Engineering and administrative systems intended to 1) Water withdrawal
improve resource efficiency are in good repair or a) Source of water = on-site (e.g. Surface withdrawal, aquifer via well) or off-site via municipal or private company service
operating at high capacity. b) Good practice is to understand where the municipal or private company service withdraws its water
2) Engineering and administrative systems for c) Good practice: A water risk assessment that considers competitive use, water quality, and scarcity has been conducted in the last 3
improved resource efficiency adhere to the hierarchy years for the facility's location using reference tools such as:
of resource efficiency when feasible, showing i) WWF Water Risk Filter,
preference (in order) for the following functions: ii) WRI Aqueduct,
a) Prevention: unnecessary consumptive iii) WBCSD Global Water Tool
processes are eliminated iv) The Water Footprint Assessment Tool
b) Minimization: Process efficiency is improved v) GEMI Local Water Tool
c) Substitution: Using a more environmentally 2) Water discharge
benign or renewable resource a) Equipment:
d) Reuse, recycling, recovery: In that order, in i) A program to evaluate the integrity of existing process wastewater collection systems:
order to maximize the benefit of resource b) Regularly test of the process wastewater system
consumption c) Correct any identified deficiencies immediately
3) Personnel
a) Wastewater treatment responsibilities include:
i) Maintenance
ii) Inspection of Wastewater Treatment Plant (WWTP)
iii) Monitoring of wastewater discharge
iv) Responding to emergencies
4) Objective setting finding is listed in C2.1
5) Hazard information (Health & Safety) finding should be noted in B8
6) Auditor guidance: Reporting on this question will include the detail of the current targets and current progress against the targets

135 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
1. Environmental emissions are evident that One or more of the following is true: 1. One of minimum requirement elements is Not Applicable
could cause imminent negative impact on the 1. Person responsible for water is untrained. missing or ineffective
community (toxic air and water emissions, 2. No control programs in place and there is a
untreated wastewater release, chemicals risk of environmental emissions
spill on hazardous substances released 3. No baseline to reduce environmental impacts
outside the facility, ...) 4. Two or more of minimum requirement
elements are missing or ineffective

Remote Verification Acceptable: NO

136
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 C8) Energy Consumption and Greenhouse Gas Emissions
Participants are to establish a corporate-wide greenhouse gas reduction goal. Energy consumption and all relevant Scopes 1 and 2 greenhouse
gas emissions are to be tracked, documented and publicly reported against the greenhouse gas reduction goal. Participants are to look for
cost-effective methods to improve energy efficiency and to minimize their energy consumption and greenhouse gas emissions.

137
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
C8.1 Energy consumption and all relevant Scopes 1 and 2 Greenhouse gas (GHG) emissions are tracked, documented and publicly reported
against the corporate greenhouse gas reduction goal
Conformance Requirements:
Site Observations Record Review
1) Greenhouse Gas emissions 1) Corporate level implementation
a) There is no significant energy consumption or GHG emissions at the a) Documented corporate policy
facility that are not tracked and documented b) GHG Reduction goal
c) Documented corporate process
d) Assigned responsibility
e) Proof of implementation
2) Facility level (in case no corporate level implementation)
a) Energy consumption
i) A baseline of energy use (by source)
ii) The sources of electricity and other energy are documented, consumption recorded and accurate by source
(1) On-site combustion: oil, coal, diesel, natural gas, propane, garbage, etc.
(2) Copies of records of total quantity of fuel combusted on-site (or easily extrapolated from fuel bills and
other purchased fuel records)
(3) Purchased electricity
(4) Renewable energy use –If facility purchases renewable energy through their utility company
b) Scope 1 and 2 Greenhouse Gas emissions are documented, consumption recorded and accurate by source and
with a description of its boundary
3) Public reporting
a) Publicly report a corporate-wide* GHG footprint (total scopes 1 & 2) as a quantitative value of total emissions. A
percentage (e.g., 90% of last year’s emissions) is unacceptable.
b) Value must represent annual emissions.

Additional assistance:
Site Observations Record Review
1) On-site combustion (incinerators, diesel generators, burning of waste on- 1) Corporate wide* = reflecting at least a significant majority (e.g. 90-95%) of corporate owned operations
site), purchased electricity (un-metered electricity consumption at the 2) Definitions
facility), significant leakage of refrigerants (from HVAC units or other a) GHG = greenhouse gases such as carbon dioxide, methane, water vapor, and nitrous oxide but also include the
refrigeration equipment), or other GHG-generating production processes chlorofluorocarbons (cfcs), hydrofluorocarbons (hfcs) and Perfluorocarbons (pfcs), as well as sulfur
(cfcs and hfcs from solvents and foams, for example). hexafluoride (SF6)
b) Scope 1 GHG emissions are all direct GHG emissions
c) Scope 2 GHG emissions are all indirect GHG emissions from consumption of purchased electricity, heat or steam.
This does not include transportation, waste generated in operations, travel, commuting, use or end of life product
treatment (Scope 3 GHG emissions)
3) Records
a) Documentation on GHG emissions

138
i) On-site combustion: oil, coal, diesel, natural gas, propane, garbage, ….

|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 ii) Copies of records of total quantity of fuel combusted on-site over the previous calendar year should be
available for review or should be easily extrapolated from fuel bills and other purchased fuel records.
iii) Purchased electricity
iv) Renewable energy use –If facility purchases renewable energy through their utility company, this should
be documented as well.
b) Description of boundary defined for reporting (such as: financial control, operational control, or equity share)
c) Description of how energy consumption and other GHG sources are converted into GHG emissions using
internationally accepted GHG protocol
4) Auditor guidance: Reporting on this question will include the detail of the current targets and current progress against
the targets

Rating:
Priority Major Minor Not Applicable
Not applicable 1. Energy and fuel consumption data is not 1. Facility and company have energy and fuel 1. Facility does not directly pay for fuel or
tracked, or significantly incomplete AND no consumption data but do not calculate their electricity (energy consumption is paid for
Scopes 1 and 2 GHG emissions data is GHG emissions and managed by building owner, and not
available for the facility or company. reported to company). For example, if
2. The responsibility could be shared corporate company is tenant in fully serviced leased
and facility then complete the relevant section building, it is expected that company will at
1 and/or 2 least make a good faith effort to obtain this
a. If implementation is done at data, or effectively estimate for the purposes
corporate level then verify 1), if not of GHG reporting.
complete then “Major”
b. if implementation at facility level
then verify 2)
c. If implementation at both levels
then verify 1) and 2) then the highest
of both rating apply
Remote Verification Acceptable: YES, unless significant energy consumption or GHG
emissions that are not documented are discovered
on-site.

139 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
C8.2 Cost-effective methods to improve energy efficiency and to minimize their energy consumption and all relevant Scopes 1 and 2
greenhouse gas (GHG) emissions are implemented.
Conformance Requirements:
Site Observations Record Review
1) Technology or management strategies to minimize energy consumption and 1) Reduction program
GHG emissions are visible. a) An adequate and effective reduction program with
2) Reduction programs are visible within the facility. i) Annual objectives
ii) Regular objective tracking
iii) Progress monitoring
iv) Adjustments made if off track
b) The programs must be structured with roles and responsibilities, written procedures, targets, monitoring and
reporting.
2) Records
a) Accurate energy and GHG emissions inventory records are maintained and available for review.
b) Inspection records of energy and GHG emissions and their points of use are maintained and available for review.

Additional assistance:
Site Observations Record Review
1) This could include: 1) Procedures to effectively manage energy consumption (may include a “start-up, shut-down” procedure for the facility,
a) Building automation technology, programmable thermostats, lighting staging for boilers and chillers, ... …) if the facility is large or complex enough to warrant these procedures
controls, or energy-efficient heating, cooling, lighting, and ventilation
technology
b) Use of on-site combustion or vehicles that are fuel efficient or use a
less GHG--intensive source (natural gas, electric, cellulosic ethanol,
…).
c) Purchasing or installing on-site renewable energy
d) Use of high-efficient collection/treatment systems to absorb/treat
cleaning agents
e) Use of refrigerants with low global warming potential (GWP) in
Heating, Ventilation, and Air Conditioning (HVAC) systems

140 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
Not Applicable 1. Company has made no discernable effort to 1. Company has made some investments or 1. Company does not pay for fuel or energy
identify opportunities to minimize energy plans to improve energy efficiency and GHG consumed on-site.
consumption and GHG emissions. emissions but has not documented these
energies and GHG emissions reductions.

Remote Verification Acceptable: NO

141
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
5. D. ETHICS

D1) Business Integrity

The highest standards of integrity are to be upheld in all business interactions. Participants shall have a zero-tolerance policy to
prohibit any and all forms of bribery, corruption, extortion and embezzlement.

142
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
D1.1 Adequate and effective policy and procedures to uphold the highest standards of integrity in all business interactions with a zero
tolerance to any and all forms of bribery, corruption, extortion and embezzlement.
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Policy
a) Adequate and effective policy and procedures to uphold the highest standards of integrity in all business
interactions with a zero tolerance to any and all forms of bribery, corruption, extortion and embezzlement
2) Investigation and sanctions
a) Adequate and effective monitoring program
i) a program to regularly monitor its business to ensure:
(1) Workers or agents do not make or accept improper offers, bribes or undue/improper advantage
(2) records verifying is not falsified and accurate.
(3) fair business, advertising and competition
(4) protection of identity and retaliation
(5) protection of personal information
b) Appropriate investigation process when there is an alleged violation including misrepresentation by workers,
managers and their agents.
c) Appropriate sanctions when a violation is confirmed/proven and preventive action plan
d) Adequate and effective procedure is in place to protect workers/employees from retribution for refusing to do
anything in Non-conformance with the “highest standard of integrity” policy and communicate/volunteer their
decision.
3) Records
a) Investigation reports on alleged violations
b) Sanctions in personnel files for proven/confirmed violations and preventive action plan
c) Personnel files leave records and disclosure records confirms no negative consequence for any
worker/employee refusing to do anything in Non-conformance with the “highest standard of integrity” policy
d) Confirmation in personnel records that the policy was communicated in an understandable form

143 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Additional assistance:
Site Observations Record Review
1) ALL Ethics investigation and sanctions findings must be listed in this AC

Rating:
Priority Major Minor Not Applicable
1. Confirmed case of Ethics breach (all of D 1. No detailed and understandable policy and One or more of the following is true: Not Applicable
section) without investigation or corrective procedures implemented 1. Partial policy or procedures or
action plan or corrective action plan not 2. Confirmed case has been documented and implementation
implemented) excluding deliberately investigated but no progress has been made 2. Confirmed case without completed corrective
misleading documents which is listed in D3.1) to implement corrective action action plan within the timeline specified in the
procedures and / or policy.
Remote Verification Acceptable: NO

144
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 D2) No Improper Advantage
Bribes or other means of obtaining undue or improper advantage are not to be promised, offered, authorized, given or accepted.
This prohibition covers promising, offering, authorizing, giving or accepting anything of value, either directly or indirectly through a
third party, in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage. Monitoring,
record keeping and enforcement procedures shall be implemented to ensure compliance with anti-corruption laws.

145
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
D2.1 No identified risk or evidence of bribes or obtaining undue or improper advantage being promised, offered, authorized, given or
accepted.
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Policy
a) Adequate and effective procedures are in place that ensure:
i) Gifts: Gifts to or from suppliers and customers is not excessive in cost and frequency.
ii) Bribes: Bribes or other methods of obtaining undue or improper advantage are not being promised, offered,
authorized, given or accepted.
iii) Conflict of interest encourages workers/employees to declare conflicts of interest
b) Ensure compliance with anti-corruption laws
2) Records
a) Declarations of conflict of interest are recorded.

Additional assistance:
Site Observations Record Review
1) If labor agents are used, then these procedures also need to be implemented at the labor agent level.
2) Investigation and sanctions findings must be listed in D1.1

Rating:
Priority Major Minor Not Applicable
1. Confirmed case of bribery, improper 1. No detailed and understandable gift or similar 1. Partial policy) or procedures or Not Applicable
advantage, corruption, extortion, or policy and procedures implemented implementation
embezzlement with no corrective action plan.
Remote Verification Acceptable: YES

146 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 D3) Disclosure of Information
All business dealings should be transparently performed and accurately reflected on Participant’s business books and records.
Information regarding participant labor, health and safety, environmental practices, business activities, structure, financial situation
and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of
records or misrepresentation of conditions or practices in the supply chain is unacceptable.

147
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
D3.1 No identified risk or evidence of misreporting, record falsification, misrepresentation or evidence of communicating inaccurate
information to the public
Conformance Requirements:
Site Observations Record Review
1) If publicly communicated company information is posted then it is accurate 1) Policy
a) Public information must not make false or misleading statements about the Auditee's products, services,
opportunities, position, ....
b) Formal program to ensure public Auditee statements are not false or misleading
Adequate and effective procedures to
i) Record: Ensure that all business dealings should be transparently performed and accurately reflected on
Participant’s business books and records
ii) Inspect: Inspect/assess/audit records verifying they are not falsified and accurate.
iii) Investigate: investigate misrepresentation by workers, managers and their agents.
2) Records
a) Financial and annual reports about the Auditee’s business operations are available and ready for review
b) Inspection and investigation records are available for review

Additional assistance:
Site Observations Record Review
1) Scope:
a) Information regarding participant labor, health and safety, environmental practices, business activities,
structure, financial situation and performance is to be disclosed in accordance with applicable regulations and
prevailing industry practices.
b) Falsification of records or misrepresentation of conditions or practices in the supply chain is unacceptable
c) Unintentional errors are out of scope for this question.
2) Records
a) Examples
i) E.g. Good accounting policies, procedures, and record keeping, internal controls to ensure the accuracy of
information
ii) E.g. Annual periodic third-party financial audit to confirm that accounts are in order
3) Auditors will cross check a number of different business records to ensure records align and are accurate.
4) NOTE: Includes all kinds of publicly communicated company information (job posting, product details, company/facility
promotion (booklet/flyer), commercial advertising, press releases, website, ...)

148 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
1. Documents are deliberately misleading 1. No detailed and understandable policy and 1. Partial policy or procedures or Not Applicable
procedures implemented implementation
Remote Verification Acceptable: YES

149
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 D4) Intellectual Property
Intellectual property rights are to be respected; transfer of technology and know-how is to be done in a manner that protects
intellectual property rights and customer and supplier information is to be safeguarded.

150
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
D4.1 No identified risk or evidence of Intellectual Property or business information loss or unauthorized disclosure (the Auditee’s own
and that of their customers/suppliers)
Conformance Requirements:
Site Observations Record Review
1) Is IP and business information visibly protected 1) Policy
a) Adequate and effective policy and program is in place to review and protect
i) The information received from suppliers, customers as part of the contracting process.
ii) IP ownership and ensure protection of IP
2) IT measures
a) Guidelines about the distribution/dissemination of information to protect information from suppliers and
customers and IP
3) Contracts
a) Non-disclosure agreement (separate or part of employment contract) for workers and management is in place

Additional assistance:
Site Observations Record Review
1) Information from suppliers and customers could include:
a) Names and contact information for key customer personnel
b) Contract pricing and volumes
c) Names of sub-contractors and materials/components suppliers, ...
d) Their identities and trademarks
e) Third-Party Intellectual Property (IP)
f) Patent records
g) Copyright-protected content.
2) Customers could include channel partner and other business relationships
3) Suppliers could include representatives, agents, sub-contractors and other business relationships
4) Investigation and sanctions findings must be listed in D1.1

Rating:
Priority Major Minor Not Applicable
Not Applicable 1. No detailed and understandable policy and 1. Partial policy or procedures or Not applicable
procedures implemented implementation
Remote Verification Acceptable: YES

151 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 D5) Fair Business, Advertising and Competition
Standards of fair business, advertising and competition are to be upheld.

152
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
D5.1 No identified risk or evidence of non-conformance with fair business, advertising and competition standards
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Policy
a) Adequate and effective policy and procedures ensuring fair business, advertising and competition standards are
upheld including
i) Safeguards are in place to prevent collusion with other companies on product pricing or other factors that
could reduce competition
ii) Monitoring procedures related to fair business, advertising and competition are in place

Additional assistance:
Site Observations Record Review
1) Investigation and sanctions findings must be listed in D1.1

Rating:
Priority Major Minor Not Applicable
Not Applicable 1. No detailed and understandable policy and 1. Partial policy or procedures or Not Applicable
procedures implemented implementation
Remote Verification Acceptable: YES

153 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 D6) Protection of Identity and Non-Retaliation
Programs that ensure the confidentiality, anonymity and protection of supplier and employee whistleblowers are to be maintained
unless prohibited by law. Participants should have a communicated process for their personnel to be able to raise any concerns
without fear of retaliation.

154
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
D6.1 No identified risk or evidence of retaliation or reduced protection of identity
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Policy
a) Adequate and effective policy and procedures ensuring protection of identity and non-retaliation are in place
including
i) Safeguards are in place to prevent reduced protection of identity and retaliation
ii) Monitoring procedures related to protection of identity and retaliation are in place
b) Adequate and effective policy and procedures to ensure protection of Whistleblowers and/or users the of the
grievance mechanism(s) (internal and external)

Additional assistance:
Site Observations Record Review
1) Investigation and sanctions findings must be listed in D1.1
2) Findings on grievance mechanisms (internal and external) are listed in E8.1

Rating:
Priority Major Minor Not Applicable
Not Applicable 1. No detailed and understandable policy and 1. Partial policy or procedures or Not Applicable
procedures implemented implementation
Remote Verification Acceptable: YES

155 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 D7) Responsible Sourcing of Minerals
Participants shall adopt a policy and exercise due diligence on the source and chain of custody of tantalum, tin, tungsten and gold in the
products they manufacture to reasonably assure that they are sourced in a way consistent with the Organization for Economic Cooperation and
Development (OECD) Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas or an equivalent and
recognized due diligence framework.

156
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
D7.1 Adequate and effective Conflict Minerals policy and management program that is designed and implemented to reasonably assure
that the tantalum, tin, tungsten and gold (3TG) in the products they manufacture are sourced in a way consistent with the OECD Guidance
for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas (OECD Due Diligence Guidance) or an equivalent
and recognized due diligence framework.

Conformance Requirements:

157
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 Site Observations Record Review
Not Applicable 1) Policy
a) Adequate and effective Supply Chain Policy and Management System that is designed and implemented to
reasonably assure the 3TG in the products they manufacture are sourced in a way consistent with the OECD Due
Diligence Guidance or an equivalent and recognized due diligence framework. The policy must:
i) Be communicated to suppliers and the public.
ii) Cover all 3TG included in the company’s products
Commit the company to exercise due diligence on the source and chain of custody of minerals in accordance
with the OECD Due Diligence Guidance
2) Corporate level implementation
a) Documented corporate policy
b) Documented corporate process
c) Assigned responsibility
d) Proof of implementation
(1) Reviewing the Management System, on an annual basis, to ensure conformance and improve where
process improvements have been identified
3) Facility level (in case no corporate level implementation)
a) Management System requirements
i) The facility shall implement the Supply Chain Policy and Management System within its own operation(s),
including:
(1) Identifying a senior management person responsible for implementation of the Management System
(2) Including 3TG due diligence sourcing requirements in written agreements and/or contracts with
suppliers.
(3) Mitigate any risks identified in accordance with the OECD Due Diligence Guidance, including the
suspension or termination of business relationships with suppliers when risk mitigation is
unsuccessful
4) Records
a) Maintaining records related to conflict minerals due diligence for a minimum of five (5) years
b) Annual review and improvement plan (if applicable)
c) Mitigation plans with suppliers if any risk is identified

5) Additional actions taken to ensure completion at due date if mitigation actions are not on track.

158 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Additional assistance:
Site Observations Record Review
1) The responsibility could be shared corporate and facility then complete the relevant section 2 and/or 3
a) If implementation is done at corporate level then verify 2), if not complete then “Major”
b) if implementation at facility level then verify 3)
c) If implementation at both levels then verify 2) and 3) then the highest of both rating apply
2) Publicly communicated=e.g. posted to the company’s website (include URL), contained within a Corporate
Responsibility Report, and/or Supplier Code of Conduct or other official public company communications.
3) Serious human rights abuses=defined in annex II of the OECD Due Diligence guidance
4) Conflict minerals= Tantalum, Tin, Tungsten and Gold or 3TG
5) Covered Countries= Democratic Republic of the Congo (DRC) and adjoining countries (Angola, Burundi, Central African
Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia
6) For rating, documentation means supplier request and two follow up requests are made if no information is received.
Rating:
Priority Major Minor Not Applicable
1. Confirmed purchasing of minerals from 1. No existence of clear Conflict Free Minerals 1. Less than 25% of 3TG sources do not have a 1. No Tin, Tungsten, Tantalum and Gold (3TG)
conflict sources in the Covered Countries and policy and/or Conflict Minerals and due-diligence and documentation in place mineral material or containing components
no documented action taken by auditee to management system, more than 25% of 3TG
address the issue. sources do not have a due-diligence and
documentation in place
Remote Verification Acceptable: NO

159 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 D8) Privacy
Participants are to commit to protecting the reasonable privacy expectations of personal information of everyone they do business
with, including suppliers, customers, consumers and employees. Participants are to comply with privacy and information security
laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.

160
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
D8.1 No identified risk or evidence of unauthorized disclosure of personal information
Conformance Requirements:
Site Observations Record Review
1) Personal information is visibly protected 1) Policy
a) Adequate and effective policy and procedures ensuring protection of personal information are in place including
i) Safeguards are in place to prevent unauthorized disclosure of personal information
ii) Monitoring procedures related to protection of personal information are in place

Additional assistance:
Site Observations Record Review
1) Scope:
a) Everyone Auditee does business with, including suppliers, customers, consumers and employees.
b) Requirements apply when personal information is
i) Collected
ii) Stored
iii) Processed
iv) Transmitted
v) Shared.
2) Investigation and sanctions findings must be listed in D1.1

Rating:
Priority Major Minor Not Applicable
Not Applicable 1. No detailed and understandable policy and 1. Partial policy or procedures or Not Applicable
procedures implemented implementation
Remote Verification Acceptable: YES

161 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
6. E. MANAGEMENT SYSTEM

E1) Company Commitment

Corporate social and environmental responsibility policy statements affirming Auditee’s commitment to compliance and continual
improvement, endorsed by executive management and posted in the facility in the language of the workers or in a language the
workers can understand.

162
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
E1.1 Adequate and effective policies/Code(s) that are endorsed by executive management, covering: A) Labor B) Health & Safety C)
Environment and D) Ethics.
Conformance Requirements:
Site Observations Record Review
1) Corporate social and environmental responsibility policy statements in a 1) Statement/Code signed/endorsed by the highest-level manager at the facility or company with a stated commitment
language understood by each worker is visible to all workers to regulatory compliance and other requirements and commitment to continuous improvement
2) The policy statement is appropriate for the nature and scope of the facility’s operations.

Additional assistance:
Site Observations Record Review
1) Requirements apply for each component. Components are Labor, Health & Safety, Environmental and Ethics. If a
component has a valid certification, then this is considered conformance for that component on this question (i.e. if a
valid ISO 14001 certificate is in place the Auditor will not verify the Environmental Management System)
2) The executive endorsement of the code can be absent when policy/Code is publicly displayed (e.g. intra or internet
site).
3) Operating Procedures: Accurate and transparent disclosure of information (example: accuracy of company records,
accurate reporting in books and records, disclosed in accordance with law / prevailing industry practices)
4) For Ethics, items/principles in BOLD must be covered at a minimum in at least one of their code of business ethics,
standards of business conduct, business principles or code of conduct or similar document. The words do not have
to match, but the principles need to be there:
a) General Ethics: conduct business with honesty/integrity (examples: avoid conflicts of interest, stealing,
extortion, embezzlement, protect corporate assets, compete fairly), protection of identity and non-retaliation
(example: whistleblower, anonymous reporting)
b) Legal compliance: Anti-Corruption or Anti-Bribery, Anti-Trust, Privacy, Intellectual Property (IP) Protection,
Responsibly Sourcing Minerals

Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One or more of the following is true: Not Applicable
1. Two or more of minimum requirement 1. No endorsement of senior management,
elements are missing or ineffective 2. One of minimum requirement elements is
2. Does not contain commitment to continuous missing or ineffective, or a system element is
improvement and legal compliance not adequately documented or is prohibited
3. Percentage of workers not aware of code 3. Percentage of workers not aware of code
content is >20% content is ≤20%
Remote Verification Acceptable: YES

163 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 E2) Management Accountability and Responsibility
The Participant clearly identifies senior executive and company representative[s] responsible for ensuring implementation of the
management systems and associated programs. Senior management reviews the status of the management systems on a regular
basis.

164
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
E2.1 Responsibilities and authorities are adequately and effectively defined and assigned for all employees/workers (senior managers
to workers) for implementation of management systems, and for compliance with laws, regulations and codes pertaining to: A) Labor
B) Health & Safety C) Environment and D) Ethics.
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Senior representative
a) A senior representative is assigned responsibility for implementing programs
i) To ensure compliance with laws and regulations and the requirements of the RBA
ii) Is authorized to implement programs, procedures and corrective actions as needed for regulatory
compliance and RBA conformance
2) Assignment
a) Responsibilities and authority of each organizational level are documented in position plans, job descriptions
and/or the facility's management system documentation
i) For normal situations
ii) For emergency situations

Additional assistance:
Site Observations Record Review
1) Requirements apply for each component. Components are Labor, Health & Safety, Environmental and Ethics. If a
component has a valid certification, then this is considered conformance for that component on this question (i.e. if a
valid third-party ISO 14001 certificate is in place the Auditor will not verify the Environmental Management System)

165 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: 1. One of minimum requirement elements is Not Applicable
1. Two or more of minimum requirement missing or ineffective, or a system element is
elements are missing or ineffective not adequately documented or is prohibited
2. No identified management representative
authorized to implement the management
system of a component

Remote Verification Acceptable: YES

166
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
E2.2 An adequate and effective management review and continuous improvement process for A) Labor, B) Health & Safety, C)
Environment and D) Ethics performance and management systems are established
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Process
a) Adequate and effective annual management system review process is in place
2) Records
a) System review meetings
b) Preventive corrective action plan following the review
c) Management review meeting presentation materials/analysis/data

Additional assistance:
Site Observations Record Review
1) Requirements apply for each component. Components are Labor, Health & Safety, Environmental and Ethics. If a component has a valid
certification, then this is considered conformance for that component on this question (i.e. If a valid ISO 14001 certificate is in place the
Auditor will not verify the Environmental Management System)
2) Management review minutes include e.g.
a) Agenda
b) Presentation material (references)
c) Date
d) Who was present (including senior manager)
e) Progress towards objectives
f) Results of Audits
g) Completion of corrective/preventive actions
h) Risks/issues
i) Other information needed to determine the effectiveness of the management system and identify improvement opportunities
j) Agreed preventive/corrective actions

167 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: 1. One of minimum requirement elements is Not Applicable
1. Two or more of minimum requirement missing or ineffective, or a system element is
elements are missing or ineffective not adequately documented or is prohibited
2. Senior management does not assess annually

Remote Verification Acceptable: YES

168
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 E3) Legal and Customer Requirements
A process to identify, monitor and understand applicable laws, regulations and customer requirements, including the requirements
of this Code.

169
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
E3.1 An adequate and effective compliance process to monitor, identify, understand and ensure compliance with applicable laws and
regulations and customer requirements pertaining to: A) Labor B) Health & Safety C) Environment and D) Ethics is established
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Process
a) Adequate and effective quarterly compliance process to maintain a current understanding of applicable legal
and customer requirements:
i) Identify
ii) Track
iii) Assess
iv) Integrate
v) Implement
vi) Records
2) Records
a) Accurate and up to date compliance register
b) A compliance calendar or reminders/tasks/calendar appointments via an e-mail system.
c) Summaries of applicable laws and regulations and the key customer requirements that impact the operations
d) New/changed operations/policies/procedures as a result of the review process for new requirements

Additional assistance:
Site Observations Record Review
1) Requirements apply for each component. Components are Labor, Health & Safety, Environmental and Ethics. If a
component has a valid certification, then this is considered conformance for that component on this question (i.e. if a
valid ISO 14001 certificate is in place the Auditor will not verify the Environmental Management System)

170 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
Not Applicable 1. Two or more of minimum requirement 1. One of minimum requirement elements is Not Applicable
elements are missing or ineffective missing or ineffective, or a system element is
not adequately documented or is prohibited

Remote Verification Acceptable: YES

171
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
E4) Risk Assessment and Risk Management
A process to identify the legal compliance, environmental, health and safety and labor practice and ethics risks associated with
Auditee’s operations Determination of the relative significance for each risk and implementation of appropriate procedural and
physical controls to control the identified risks and ensure regulatory compliance.

172
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
E4.1 An adequate and effective risk management process to identify, assess, and minimize/mitigate/control its risks in the areas of: A)
Labor C) Environment and D) Ethics is in place
Conformance Requirements:
Site Observations Record Review
1) Control measures are in place for identified risks 1) Process
a) Adequate and effective risk assessment process using the hierarchy of controls or equivalent process is in place
to identify the most significant risks (including applicable legal requirements and applicable customer
requirements).
b) The risk assessment is updated when there is a Significant Change
c) Any identified risk has an action plan to minimize such risk and procedural controls and/or improvement
objective.
d) Effectiveness of controls is evaluated on a regular basis
2) Records
a) Formal risk assessment reports
b) Corrective/preventive action plan for identified risks
c) Procedural controls are documented
d) Where controls are not yet in place an implementation plan (with owners and due date) is in place and on track

Additional assistance:
Site Observations Record Review
1) Requirements apply for each component. Components are Labor, Health & Safety, Environmental and Ethics. If a
component has a valid certification, then this is considered conformance for that component on this question (i.e. if a
valid ISO 14001 certificate is in place the Auditor will not verify the Environmental Management System)
2) Scope of the risk assessment:
a) Every site operation/process
b) Physical location
c) Consideration of multiple chemical exposures combined physical and chemical exposure effects, and extended
work periods (as applicable)
3) For Ethics, - Risk assessment considers business circumstances (country of operations, stakeholders, ...) and covers
at minimum honesty, integrity, intellectual property protection, bribery, corruption, fraud/embezzlement,
embezzlement, extortion, legal, ethical, fair business/marketing practices, reporting violations, whistleblower
protection, kickbacks, bribes, privacy, unlawful payments, ...
4) Health and Safety Risk assessment is covered in B1.2

173 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
1. Imminent and significant impact are One or more of the following is true: One or more of the following is true: Not Applicable
confirmed on facility, life, limb or community 1. Two or more of minimum requirement 1. One of minimum requirement elements is
without action elements are missing or ineffective missing or ineffective, or a system element is
2. No risk process adequate for the scope and not adequately documented or is prohibited
nature of the operations and no controls in 2. Risk process adequate for the scope and
place nature of the operations AND risk
assessment performed but no adequate
controls in place
3. No consideration of multiple chemical
exposures

Remote Verification Acceptable: YES

174
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 E5) Improvement Objectives
Written performance objectives, targets and implementation plans to improve the Participant’s social, environmental, and health and
safety performance, including a periodic assessment of Participant’s performance in achieving those objectives.

175
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
E5.1 An adequate and effective performance management process for A) Labor, B) Health & Safety, and D) Ethics, including setting
performance (improvement) objectives and targets, developing and implementing improvement plans, regularly reviewing progress
toward achieving targets, and making appropriate adjustments if needed is in place
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Process
a) Adequate and effective annual performance management process within formal and communicated indicators,
objectives and targets
b) Additional action plans if indicator, objective or target is off track
2) Records
a) Formal target, indicator and objective tracking
b) Regular progress reporting
c) System review meetings
d) Preventive corrective action plan following the review
e) Management review meeting presentation materials/analysis/data

Additional assistance:
Site Observations Record Review
1) Requirements apply for each component. Components are Labor, Health & Safety, Environmental and Ethics. If a
component has a valid certification, then this is considered conformance for that component on this question (i.e. If a
valid ISO 14001 certificate is in place the Auditor will not verify the Environmental Management System)
2) Process
a) Scope of indicators, objectives and targets:
i) Consideration of risk assessment results
ii) Legal and regulatory requirements
iii) Company standards/requirements.
3) The process should also include
a) Assignment of owners
b) Implementation plans
c) Completion dates
d) Communication of objectives to workers (as appropriate).
e) How frequently progress in meeting objectives is reviewed
f) Objectives and targets are clearly designed to achieve continual improvement
4) Requirements apply for each component. Components are Labor, Health & Safety, Environmental and Ethics. If a
component has a valid certification, then this is considered conformance for that component on this question (i.e. If a
valid ISO 14001 certificate is in place the Auditor will not verify the Environmental Management System)
5) Management review minutes include e.g.
a) Agenda

176
b) Presentation material (references)

|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 c) Date
d) Who was present (including senior manager)
e) Progress towards objectives
f) Results of Audits
g) Completion of corrective/preventive actions
h) Risks/issues
i) Other information needed to determine the effectiveness of the management system and identify improvement
opportunities
6) Agreed preventive/corrective actions
7) Auditor guidance: Reporting on this question will include the detail of the current targets and current progress against
the targets
8) Environment objectives, targets and performance are addressed in C2.1

Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One or more of the following is true: Not Applicable
1. Two or more of minimum requirement 1. One of minimum requirement elements is
elements are missing or ineffective missing or ineffective, or a system element is
2. No targets established not adequately documented or is prohibited
3. No review takes place on progress 2. Targets are established but no review takes
4. Senior management does not assess annually place
3. No corrective actions taken if progress is off
track
Remote Verification Acceptable: YES

177 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 E6) Training
Programs for training managers and workers to implement Participant’s policies, procedures and improvement objectives and to
meet applicable legal and regulatory requirements.

178
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
E6.1 An adequate and effective training process is established for all managers/workers on all policy/procedures/job related aspects
and performance targets related to A) Labor, B) Health and Safety, C) Environment, and D) Ethics
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Process
a) adequate and effective training to workers/managers:
i) New employee orientation plan
ii) Training needs analysis
iii) Training plan
iv) Training material
v) Training records
vi) Training frequency
vii) Training efficiency verification
b) Minimum training topics are covered
2) Evaluation
a) The training programs will be evaluated on a regular basis not exceeding 3 years or sooner if there is a
Significant Change
3) Records
a) Training records include a verification of training effectiveness
b) Training evaluation reports and corrective action if required
c) Educational materials

Additional assistance:
Site Observations Record Review
1) This includes conformance section training – this section must always be completed even if a valid systems certificate
is available (e.g. ISO 14001 for environment)
2) Health & Safety training is listed in B8
3) For ethics: this includes workers but also all subcontractors, Suppliers, business partners and other relevant parties
4) Minimum training topics
a) Labor
i) Freely Chosen Employment (avoidance of forced, involuntary or exploitative prison, indentured, bonded
(including debt bondage), trafficked or slave labor)
ii) Worker Terms and Conditions
iii) Non-retention of personal documentation
iv) Freedom of movement
v) Legal minimum working age
vi) Young worker protection
vii) Apprentice/Intern/Student Worker employment
viii) Working hours including overtime

179 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 ix) Mandated breaks, holidays and vacation days, including time off when ill or for maternity leave
x) Wages statement and wage calculation
xi) Disciplinary procedures
xii) Non- discrimination and harassment
xiii) Reasonable accommodation for religious practices
xiv) Freedom of Association/Collective Bargaining and peaceful assembly
b) Environment
i) Reduction programs
ii) Hazardous waste handling, storage and disposal
iii) Solid waste handling, storage and disposal
iv) Air emissions and air emission control systems
v) Material restriction
vi) Water use, discharge and internal water channel contamination protection
vii) Storage and disposal
viii) GHG/ Energy use, reduction and maintaining energy and fuel-consuming operations
c) Ethics
i) Upholding the highest standards of integrity in all business interactions
ii) Obtaining undue or improper advantage being promised, offered, authorized, given or accepted
iii) Intellectual Property Protection
iv) Fair Business, Advertising and Competition
v) Non-retaliation or protection of identity
vi) Purchasing of the 3TG minerals does not finance or benefit armed groups or contribute to serious human
rights abuses in Conflict-Affected and High-Risk Areas
vii) Unauthorized disclosure of personal information
d) Management Systems
i) Responsibilities and authorities are adequately and effectively defined
5) Grievance and complaints systems

180 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One or more of the following is true: Not Applicable
1. Two or more of minimum requirement 1. One of minimum requirement elements is
elements are missing or ineffective missing or ineffective, or a system element is
2. Two or more focus areas are missing in the not adequately documented or is prohibited
communications (policy, performance, 2. One focus area is missing in the
practice, expectations) communications (policy, performance,
practice, expectations)

Remote Verification Acceptable: YES

181
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 E7) Communication
Process for communicating clear and accurate information about Auditee’s policies, practices, expectations and performance to
workers, Suppliers and customers.

182
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
E7.1 An adequate and effective worker/manager, Supplier and customer communication/reporting process for A) Labor, C)
Environment, and D) Ethics policies, practices and performance is established
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Process
a) Adequate and effective worker/manager, Supplier and customer communication/reporting process to Suppliers
is in place
i) Suppliers
(1) Correspondence to Supplier management
(2) Contract terms and conditions requiring Suppliers to conform to the RBA code and comply with all
applicable AC
ii) Customers
(1) Recruitment practices and performance (including freely chosen employment, e.g. Demographics of
labor and list of labor agents/ contractors with percentage of workforce, costs to workers (in total
absolute numbers and per contract base) and labor agent/contractor fees).
iii) Workers / Managers
(1) The minimum communication topics are covered
2) Evaluation
a) The communication programs will be evaluated on a regular basis not exceeding 3 years or sooner if there is a
Significant Change
3) Records
a) Communications records include a verification of communication effectiveness
b) Educational materials
c) Presentations to Suppliers

183 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Additional assistance:
Site Observations Record Review
1) This includes conformance section communications – this section must always be completed even if a valid systems
certificate is available (e.g. ISO 14001 for environment)
2) Health & Safety communications is listed in B8
3) Submitting SAQ to customers does not qualify as disclosure/communication to customers
4) Minimum Communications topics
a) Labor
i) Freely Chosen Employment (avoidance of forced, involuntary or exploitative prison, indentured, bonded
(including debt bondage), trafficked or slave labor)
ii) Worker Terms and Conditions
iii) Non-retention of personal documentation
iv) Freedom of movement
v) Legal minimum working age
vi) Young worker protection
vii) Apprentice/Intern/Student Worker employment
viii) Working hours including overtime
ix) Mandated breaks, holidays and vacation days, including time off when ill or for maternity leave
x) Wages statement and wage calculation
xi) Disciplinary procedures
xii) Non- discrimination and harassment
xiii) Reasonable accommodation for religious practices
xiv) Freedom of Association/Collective Bargaining and peaceful assembly
b) Environment
i) Reduction programs
ii) Hazardous waste handling, storage and disposal
iii) Solid waste handling, storage and disposal
iv) Air emissions and air emission control systems

184
v) Material restriction

|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 vi) Water use, discharge and internal water channel contamination protection
vii) Storage and disposal
viii) GHG/ Energy use and reduction
c) Ethics
i) Upholding the highest standards of integrity in all business interactions
ii) Obtaining undue or improper advantage being promised, offered, authorized, given or accepted
iii) Intellectual Property Protection
iv) Fair Business, Advertising and Competition
v) Non-retaliation or protection of identity
vi) Purchasing of the 3TG minerals does not finance or benefit armed groups or contribute to serious human
rights abuses in Conflict-Affected and High-Risk Areas
vii) Unauthorized disclosure of personal information
d) Management systems
i) Grievance and complaints systems

Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One or more of the following is true: Not Applicable
1. Two or more of minimum requirement 1. One of minimum requirement elements is
elements are missing or ineffective missing or ineffective, or a system element is
2. Two (2) or more focus areas are missing in not adequately documented or is prohibited
the communications (policy, performance, 2. One (1) focus area are missing in the
practice, expectations) communications (policy, performance,
practice, expectations)

Remote Verification Acceptable: YES

185 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 E8) Worker Feedback, Participation and Grievance
Ongoing processes, including an effective grievance mechanism, to assess workers’ understanding of and obtain feedback on or
violations against practices and conditions covered by this Code and to foster continuous improvement. Workers must be given a safe
environment to provide grievance and feedback without fear of reprisal or retaliation

186
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
E8.1 An adequate and effective grievance/complaint process where work-related and Code-related grievances or complaints without
fear of reprisal or intimidation is established can be confidentially communicated
Conformance Requirements:
Site Observations Record Review
1) Grievance and complaint channels are clearly communicated 1) Process
2) Internal communication of the grievance mechanism must be in workers’ a) Adequate and effective process to anonymously report grievances and complaints without fear of reprisal, which
native language(s) and visible is internal (for workers and staff) and external (for workers of suppliers, local community or interested actors
AND Whistleblowers)
b) Clear grievance channels so anyone is comfortable reporting grievances and so that reporting is encouraged
2) Investigation and actions
a) Auditee shall promptly investigate the validity of the any grievance or complaint and take prompt remedial action
if the claim is valid
b) All who file a grievance or complaint shall have their identity protected and Auditee will ensure a no reprisal or
intimation approach
3) Records:
a) Grievance/complaint records are in place for a period of at least 12 months
b) Workers are provided with written information on how to report grievances and complaints

Additional assistance:
Site Observations Record Review
1) This includes conformance section communications – this section must always be completed even if a valid systems
certificate is available (e.g. ISO 14001 for environment)
2) If finding of retaliation is regarding an ethics violation or the identity of a grievant is not protected, the finding should
be reported in D
3) Auditor guidance: evidence to show actions have been taken for the grievance/complaints in the past 12 months” may
need to spot check 1 or 2 case records.

187 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
1. Confirmed case not investigated or without 1. Two or more of minimum requirement 1. One of minimum requirement elements is Not Applicable
corrective action plan elements are missing or ineffective missing or ineffective, or a system element is
2. No anonymous reporting channels not adequately documented
3. No action has been taken/recorded for the
grievance/complaint for 3 months
Remote Verification Acceptable: NO

188
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
E8.2 An adequate and effective process to solicit and encourage worker participation, input and feedback for improvement
Conformance Requirements:
Site Observations Record Review
1) Feedback channels are clearly communicated and visible (suggestion box, 1) Process
...) a) Adequate and effective process to obtain worker input and feedback such as:
i) Worker surveys
ii) Suggestions boxes
iii) Worker focus groups
iv) Joint worker-management committees
v) Worker/union representatives
vi) Process improvement teams.
2) Evaluation and actions
a) Auditee shall promptly evaluate the validity of the any input of feedback and take prompt action if the
input/feedback is valid
3) Records:
a) Input/feedback records are in place for a period of at least 12 months
b) Workers are provided with written information on how to provide input/feedback for improvement
c) Action plans are available, implemented or on track.

Additional assistance:
Site Observations Record Review
1) Requirements apply for each component. Components are Labor, Health & Safety, Environmental and Ethics. If a
component has a valid certification, then this is considered conformance for that component on this question (i.e. if a
valid third-party ISO 14001 certificate is in place the Auditor will not verify the Environmental Management System)

189 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
Not Applicable 1. No feedback mechanism(s) in place 1. One of minimum requirement elements is 1. No worker communication
missing or ineffective, or a system element is
not adequately documented or is prohibited

Remote Verification Acceptable: NO

190
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 E9) Audits and Assessments
Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the Code and customer
contractual requirements related to social and environmental responsibility.

191
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
E9.1 An adequate and effective self-audit process to periodically assess conformance with the RBA Code pertaining to: A) Labor B)
Health & Safety C) Environment and D) Ethics.
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Process
a) Adequate and effective self-audit process to periodically assess conformance with:
i) Applicable regulatory requirements
ii) RBA Code requirements
iii) Own policies, standards and management system
iv) Other requirements to which the facility subscribes
b) Audit findings are reviewed by senior management.
2) Records
a) Self-audit Reports
b) Corrective Action Plans a s a result of the Self Audit, additional actions if the Corrective Action Plan is off-track

Additional assistance:
Site Observations Record Review
1) Requirements apply for each component. Components are Labor, Health & Safety, Environmental and Ethics. If a
component has a valid certification, then this is considered conformance for that component on this question (i.e. if a
valid third-party ISO 14001 certificate is in place the Auditor will not verify the Environmental Management System)
2) Audit scope:
a) All areas of the facility,
b) All processes, physical conditions and work practices
c) Review of documents and records
d) Interviews with individuals responsible for SER.

192 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One or more of the following is true: Not Applicable
1. No Audits carried out 1. One of minimum requirement elements is
2. Two or more of minimum requirement missing or ineffective, or a system element is
elements are missing or ineffective not adequately documented or is prohibited
3. Scope does not include regulatory compliance 2. Scope includes regulatory compliance but not
customer requirements

Remote Verification Acceptable: YES

193
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 E10) Corrective Action Process
Process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and
reviews.

194
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
E10.1 Has established an adequate and effective corrective action process to rectify and close Non-conformances for A) Labor B)
Health & Safety C) Environment and D) Ethics.
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Process
a) adequate and effective corrective action process is in place which contains the following:
i) Corrective action reports/plans and tracking tables
ii) additional actions are taken when a corrective action is off track
iii) A demonstrated link between the CAP and the performance management objectives and targets.
iv) Closure of action items is confirmed by a management representative after verification by the appropriate
person
2) Records
a) Records documenting the non-conformance
b) Corrective action plan for each non-conformance
c) Progress reports on the Corrective Action plan
d) Closure verification reports (with mgmt. confirmation)
e) Copies of any regulatory citations/violation notices received in the past three years, including any
communications with the agencies are available for review.

Additional assistance:
Site Observations Record Review
1. Requirements apply for each component. Components are Labor, Health & Safety, Environmental and Ethics. If a
component has a valid certification, then this is considered conformance for that component on this question (i.e. if a
valid third-party ISO 14001 certificate is in place the Auditor will not verify the Environmental Management System)
2. Scope of corrective action plan:
a. All identified non-conformances identified via internal or external Audits, assessments, inspections, investigations
and reviews against with the RBA Code including legal and customer requirements
3. Corrective action reports/plans and tracking tables
a. Root cause analysis of the finding to ensure the system gap is addressed
b. Specific corrective actions
c. Owners of the action
d. Due dates are established to address all Audit issues.
4. appropriate person = auditor, inspector, officer of the party which determined the non-conformance or their designate
5. If closure was not verified by an independent third party or the original government agency, Auditor must verify closure
6. Auditor guidance: General public record search by Auditors is performed to learn if the regulatory authorities have
imposed corrective action or penalties in last 3 years for each component.

195 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One or more of the following is true: The following are true:
1. Two or more of minimum requirement 1. One of minimum requirement elements is 1. No Audit or evaluation performed
elements are missing or ineffective missing or ineffective, or a system element is 2. Auditee has NOT been subject to any labor
2. One or more unaddressed regulatory actions not adequately documented or is prohibited regulatory actions in the past 3 years. 3 data
or penalties. 2. Regulatory actions or penalties are points are required to show there was no
addressed but off track and no corrective case in the past 3 years.
actions are taken to get them back on track

Remote Verification Acceptable: YES

196|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 E11) Documentation and Records
Creation and maintenance of documents and records to ensure regulatory compliance and conformity to company
requirements along with appropriate confidentiality to protect privacy.

197
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
E11.1 Adequate and effective documentation and records process with appropriate levels of access to ensure privacy for A) Labor, B)
Health & Safety, C) Environment, and D) Ethics
Conformance Requirements:
Site Observations Record Review
1) Documents are securely stored with authorized access only 1) Process
a) Adequate and effective documentation and records process with appropriate retention (on and off site) and
appropriate levels of access to ensure privacy conforming to
i) Regulatory (including record retention laws)
2) Records
a) A listing/table of documents and records retained required is available for review
b) Record retention conforms to the requirements
c) Minimum records are available for review

Additional assistance:
Site Observations Record Review
1) Requirements apply for each component. Components are Labor, Health & Safety, Environmental and Ethics. If a
component has a valid certification, then this is considered conformance for that component on this question (i.e. If a
valid third-party ISO 14001 certificate is in place the Auditor will not verify the Environmental Management System)
2) Minimum records:
a) Records of wages paid, and hours worked
b) Verification of worker age
c) Financial Audit reports
d) Non-Disclosure Agreements (NDAs)
e) Contract terms and conditions
f) Self-Audit reports
g) Regulatory compliance evaluations
h) Risk assessments
i) Work practices and procedures
j) Performance in meeting objectives and targets
k) Reports of inspections by regulatory agencies
l) Incident investigations
m) Worker complaints
n) Training records
o) Management System Review minutes and action items
p) Corrective action records.
q) Conflict of interest declarations are available in personnel files

198 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One or more of the following is true: Not Applicable
1. Two or more of minimum requirement 1. One of minimum requirement elements is
elements are missing or ineffective missing or ineffective, or a system element is
2. Does not meet regulatory requirements not adequately documented or is prohibited
2. Meets regulatory requirement but not
customer requirements

Remote Verification Acceptable: NO

199
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
 E12) Supplier Responsibility
Process to communicate Code requirements to Suppliers and to monitor Supplier compliance to the Code.

200
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
E12.1 The RBA Code requirements have been communicated to the next tier major Suppliers
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Corporate level implementation
a) Documented corporate policy
b) Documented corporate goal
c) Documented corporate process
d) Assigned responsibility
e) Proof of implementation
2) Facility level (in case no corporate level implementation)
a) Process
i) Suppliers
(1) Supplier program (identification of Major Suppliers, definition of what is major)
ii) Communication
(1) Adequate and effective communication process with its Major Suppliers on the code and its requirements or inserted the
requirements of the code and its provisions into the contract it has with Major Suppliers.
iii) Contracts
(a) Suppliers
(i) Enforcement language on the implementation of the RBA Code
(b) Labor Agents and Contractors
(i) Enforcement language on the implementation of the RBA Code regarding Labor and Ethics CA
(ii) Compliance with legal requirements in both home and sending country.
(iii) Workers can resign without penalty
(iv) Conform with all AC regarding workers in their operations
b) Records
i) Contract with Suppliers and Labor Agents and Contractors
ii) Communication materials to Suppliers and Labor Agents and Contractors
iii) Enforcement notification to Suppliers and Labor Agents and Contractors

Additional assistance:
Site Observations Record Review
1) * =sample size is square root of total workers on site of Suppliers and through a labor agent/contractor or 5 workers, whichever is larger
2) Penalty includes no threat of punishment, fines, violence, or withholding wages
3) Supplier is determined by the criteria defined by the Auditee (annual spending, critical component to core business, more than once purchase, within
ICT industry supply chain, ...). For the scope of this code provision the “next tier major supplier” definition will always include any labor
agents/contracts and on-site service providers that fall outside the scope of sections A3 and A4.
4) Additional specific forced labor requirements for Labor Agents and Contractors are listed in A1. Forced labor findings Labor Agents and Contractors
are rated in A1
5) Hazardous waste vendors’ findings /corrective action plans which are missing / off track are rated in C3.

201
6) Auditor guidance: Determining which suppliers are a Supplier (= “next tier Major Supplier”) is a process which must be verified during the audit

|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One or more of the following is true: No Suppliers
1. There is no RBA Supplier implementation 1. RBA Supplier implementation procedures
procedure and there are no documented exist but the percentage of Suppliers that
communication vehicles with Suppliers. have not been communicated to is ≥20%
2. Percentage of workers working thru Labor 2. Percentage of workers working thru Labor
Agents and Contractors that cannot state how Agents and Contractors that cannot state how
their employment terms and conditions meet their employment terms and conditions meet
the relevant labor requirements of the RBA the relevant labor requirements of the RBA
code is >20%* code is >5% and ≤20%*
3. The responsibility could be shared corporate
and facility then complete the relevant section
1 and/or 2
a. If implementation is done at
corporate level then verify 1), if not
complete then “Major”
b. if implementation at facility level
then verify 2)
c. If implementation at both levels
then verify 1) and 2) then the highest
of both rating apply
Remote Verification Acceptable: YES (NO, if non-conformance for Labor Agents and
Contractors)

202
|
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
E12.2 Adequate and effective process to ensure that the Suppliers implement the RBA Code
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Corporate level implementation
a) Documented corporate policy
b) Documented Corporate Goal
c) Documented corporate process
d) Assigned responsibility
e) Proof of implementation
2) Facility level (in case no corporate level implementation)
a) Process
i) RBA code implementation process for Suppliers is available and includes
(1) A risk assessment.
(a) If a self-reported risk assessment is used such as an SAQ then information needs to be validated and/or an Audit
performed to verify risk information.
(b) An audit (VAP or CMA) or an AMA (if done by a third-party Qualified Audit Firm is accepted).
(2) An obligation to go through the CAP process with the Supplier If non-conformances are detected
(3) A commitment to not immediately de-source at a priority non-conformance discovery state but only at the non-
implementation of the CAP process
b) Records
i) Verification visit reports for self-reported risk assessment
ii) An Audit (CMA or VAP), an AMA (if done by third-party qualified Audit Firm is acceptable)
iii) A corrective action plan for non-conformance areas identified
iv) A verification mechanism that corrective actions are implemented
v) Review of records related to A3 for on-site service provider workers as appropriate
vi) Review of records related to A4 for on-site service provider workers as appropriate

203 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e
Additional assistance:
Site Observations Record Review
1) Supplier is determined by the criteria defined by the Auditee (annual spending, critical component to core business, more than once
purchase, within ICT industry supply chain, ...). For the scope of this code provision the “next tier major supplier” definition will always
include any labor agents/contracts and on-site service providers (such as security guards, janitorial services, ...) that fall outside
the scope of sections A3 and A4.
2) If an alternative risk-based approach exists (in lieu of a fixed number of assessment/audits) there is documented criteria, guidelines,
execution of assessments/audits and finding closure tracking
3) Remote / desk-audit or focused audit processes and guidelines used on smaller, specialized facilities or service providers where a
full RBA audit is not appropriate
4) Additional specific forced labor requirements for labor agents/contractors are listed in A1.
5) Hazardous waste vendors’ findings /corrective action plans which are missing / off track are rated in C3.
6) Forced labor findings for labor agents or contractors are rated in A1

Rating:
Priority Major Minor Not Applicable
1. For indirect full time assigned workers of on- One or more of the following is true: 1. One of minimum requirement elements is 1. No Suppliers to facility
site service providers a priority non- 1. Two or more of minimum requirement missing or ineffective, or a system element is
conformance is confirmed on provision A3 or elements are missing or ineffective not adequately documented or is prohibited
A4 2. No CAP in place for the majority of Suppliers
(where applicable)
3. The responsibility could be shared corporate
and facility then complete the relevant section
1 and/or 2
a. If implementation is done at
corporate level then verify 1), if not
complete then “Major”
b. if implementation at facility level
then verify 2)
c. If implementation at both levels
then verify 1) and 2) then the highest
of both rating apply

Remote Verification Acceptable: YES (NO, if non-conformance for labor

agents/contractors)

204 |
© RBA VAP Operations Manual v7.0.0 RBA Public January 2021

P a g e