VERIFYING THE SELF-ASSESSMENT QUESTIONNAIRE
　　In completing the Self-Assessment Process, the following lists each question from the Self-Assessment Questionnaire and the evidence that must be
verified.
                       

　　PERSONNEL ISSUES
　　Question 1.1 Does the factory obtain current information on local and national laws and　regulations, and incorporate this information in its
business practices?

　　The workers should be compensated according to the local and national labor laws. The payrolldepartment should have the latest copies of these laws 
and amendments on file. These laws should cover, but not be limited to the following areas:   

　　Wages and hours.
    Legal benefits.
    Minimum age for employment and related restrictions.
    Health and safety standards.
    Employment discrimination.
    General labor law.
    The factory should have a procedure that will ensure that the labor laws and regulations are being followed. There should be a manager or supervisor
responsible for monitoring and updating these laws. Any new laws should be adapted as soon as possible.

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

    If the factory uncovers a violation, that violation must be corrected as soon as possible. The factory should document the violation and what was done to correct it. There should be a procedure to prevent the violation from re-occurring.

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

    Question 1.2 Does the factory prohibit any condition within the facility, building and/or equipment that could cause injury or death to the workers, or any violation of law or a standard?

    An unsafe condition is anything that can cause injury or death to the worker. The factory should have a procedure for monitoring safety conditions within the  facility. This would include the building and all property that is attached to the building and owned, or  used by the factory. There should also be a procedure for monitoring equipment and machinery for unsafe conditions. These procedures should be monitored by a manager or supervisor. This can be
anyone that the factory designates, however,it is usually the responsibility of the Safety Manager or Safety Supervisor. Safety issues concerning machinery and equipment are usually monitored by an Equipment Maintenance Manager or
Supervisor.    

    The building should be inspected on a regular basis for unsafe conditions. Unsafe conditions should be repaired as soon as possible. Building inspection
records should be maintained indicating the type of inspection performed, date of the inspection and  the results of the inspection. Any repairs made should also be listed.

    Machinery and equipment should be inspected and  maintained on a regular basis. Defective machinery and equipment should not be used until the proper repairs have been made. Equipment inspection records should be maintained listing the type of inspection, date of the inspection, the results of the inspection and what repairs were made.

    Any repairs made should also be listed.

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

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

    However, there are situations where a JCPenney standard is more stringent than local or national law. When this occurs, the JCPenney standard must be
followed.   

    Question 1.3 Does the factory effectively prohibit convict, involuntary, and forced labor?
    The use of convict, involuntary, indentured or forced labor of any kind is prohibited. There are no exceptions.
                       

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

    Even though there are conditions where it is permitted  to employ criminals under local or national law, it is expressly forbidden to import any product into the United States under United Stated Customs Laws, if that product was produced by convict labor.
                       

    Involuntary Labor or Forced Labor
    Anyone being forced to work against their will is  considered involuntary or forced labor. Workers must be given complete freedom of movement to leave the  facility at any time. Factories have the  right to impose restrictions on workers entering the facility or entering certain rooms within the facility but should never prohibit workers from leaving.
                       

    Indentured Labor    

    Workers should never be forced to work by contract or any other means. Workers should never be forced to work to pay off a debt for themselves, a
family member or anyone else by signing a  contract.
                       

    Worker Contracts
    In some factories workers are required to sign an  employment contract. These contracts will usually list the job description, job duties, disciplinary  procedures, overtime requirements and the length of time that the contract is in effect. Some contracts are  open ended. That is, the contract may be written with no ending date. If the contract is open 
ended, there must be a provision that will end the contract when the worker resigns the job. Employment   contracts must not include anything that can
 be interpreted as forcing the worker to work. Workers  must be allowed to resign at any time.
                       

    Occasionally factories use third party agents or brokers  to hire workers. If third parties are used to hire workers, the workers’ wages must be paid directly  to the worker and not the agency or broker. It  is the factories responsibility to ensure that third  party agents or brokers supply legal workers that are not convicts, indentured or forced to work in any way.
                       

    Security guards employed by the factory, or security   agencies contracted for their services, must not engage in practices that will cause workers to stay in  the factory and work against their will. Security guards should be limited to normal security functions   such as protecting the factory and products produced and the security of the workers and other   factory personnel.
                       

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

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

    Question 1.4 Does the factory obtain documentation for  proof of age and eligibility for  employment from all potential workers prior to hiring?

    When hiring workers, the factory should verify proof of  age and eligibility to work according to local and national laws or JCPenney standards. This proof must  be in a form of legally acceptable documents. The following are examples of the type of  documents that are acceptable:
                       

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

    Official birth certificate.
    Official identification card.
    Official school records.
    Proof of residence.
    Immigration or other legal papers as required.
    A statement of age containing:
    Employee signature.
    Employee identification number or other means of  identification.
    Date of signature.

    All workers should fill out an employment application  listing their name, address, date of birth, place  of birth, citizenship, type of job applied for and any  information as required by local and national law.

    This application should be signed by the worker.

    The factory should have a procedure that explains to the  workers minimum age and eligibility  requirements for the job applied for. The factory should   explain all benefits that the workers are  entitled to. This includes social security (medical and  pension), savings, bonus, overtime hours, overtime pay, worker contracts, job requirements,  disciplinary procedures, dormitory, meals and anything that will affect the worker.

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

    All worker personnel records should be periodically reviewed to ensure that the proper documents are  on file and correctly updated.

    Question 1.5 Does the factory prohibit the hiring of  workers under the legal age or  JCPenney standard, or ineligible workers, and does the  factory keeps copies of age and eligibility?

    It is the responsibility of the factory to ensure that  all workers hired are of legal age and meet the eligibility requirements of the country where the   factory is located. If it is determined that these requirements are below the JCPenney standards, then the  JCPenney standards will apply.
                       

    The factory should have a procedure to screen all  workers prior to hiring, to ensure that they meet all applicable age and eligibility requirements. Copies of  all applicable proof should be kept on file for all  workers.

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

    Question 1.6 Does the factory effectively prohibit all  forms of harassment, abuse, and physical and/or verbal abuse?

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

    The factory should expressly prohibit all forms of  harassment, verbal and/or physical abuse. This includes, but is not limited to:
     

    Physical or verbal coercion.
    Sexual abuse.
    Harassment, or abuse in the form of disciplinary action.
    Any harassment or abuse from any person, such as  security guards, or any manager, supervisor  or worker.

    Question 1.7 Does the factory have procedures to ensure  employees are compensated in accordance with local laws and regulations?

    The factory should have a payroll procedure that will  ensure workers are compensated in accordance  with local and national laws. The factory should have a  manager or supervisor responsible for the  payment of wages and all issues relating to wages. There  should be an itemized listing of all deductions. These procedures should include, but not be  limited to:
     

    A detailed method of payment as appropriate.
    Check.
    Cash.
    Direct deposit.
    The basis for payment.
    Hourly.
    Weekly.
    Monthly.
    Piece rate.
    Combination (Hourly and piece rate).
    

    A detailed procedure for wage calculation where  applicable.

    Quota for piece rate or hourly calculation.
    Adjustment to meet minimum.
    Hourly or monthly minimum rate.
    Bonus or other incentives.
    Itemized deductions.
    Social Security (Medical and/or pension).
    Required local and national taxes.
    Issuing and repayment of loans.
    Any other deductions.
  

    Frequency of payment.
    Weekly.
    Monthly.
    Other.
    Specific length of the normal work day.
    Number of hours.
    Start and finish time.
    Define the normal week.
    Number of consecutive days.
    Specific days of the week.
    Rest and meal breaks.
    Number of breaks.
    Length of break.
    Time of day or shift.
    Designate days off.
    Normal day(s) off each week.
    Holidays (Legal and/or religious).
    Vacation.
    Define overtime.
    Hours.
    Compensation rate.
    The factory should have a detailed pay slip that shows  all the deductions made and the method of calculation. If workers receive cash payments there  should be a master payroll record with each  workers’ signature indicating that they received their   pay.

    The workers should be notified in writing of any changes  in their actual pay and/or payroll procedures and the reasons for these changes.

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

    Any worker's complaints regarding wages must be  investigated immediately. If it is determined that the workers were not correctly paid, an adjustment must  be made immediately.

     Question 1.8 Are factory workers, at the time of hiring, made aware of their legal rights regarding hours worked, and wage compensation?

    When factory workers are hired they should receive an  explanation of their legal rights concerning the  working hours of the factory. They should be told if  overtime is required and how many overtime hours they can expect to work daily, weekly and monthly.

    They should be given an explanation of the laws concerning overtime.

    A written explanation of wage and overtime laws should  be provided to the workers. This explanation  should be signed by the worker and a copy should be kept in the worker’s file.

    The factory should periodically review the laws  concerning hours worked and wage compensation to  ensure they are in compliance with the most current  laws. Any areas that are not current should be  corrected. Copies of the latest laws should be kept on  file.

    Question 1.9 Does the factory prominently post minimum  wage rates, allowance information, benefits policies, and regular and overtime  wages in the native language(s) of the factory workers and management personnel?

    The factory should list its policies concerning minimum   wage rates, regular working hours, overtime  hours and benefits. Any applicable local and national   wage laws should also be listed. These postings should be located in prominent areas, i.e., the  worker entrance, time clock, or cafeteria; so the workers can read them at any time.

    All postings should be in the native language of the   factory workers and factory management personnel. In the event that the factory hires workers   that speak a language other than the language  of the country where the factory is located, these  postings should also be in that language. It is possible that the factory will need postings in more  than one language.

   Question 1.10 Does the factory have, utilize, and  maintain an organized payroll system including an accurate time recording device?

    The payment of wages can be a complicated process. To  ensure that the workers are accurately paid, an organized payroll system should be used. A   computer payroll system is recommended for accuracy and consistency. All methods of payment,   including time work, piece work, incentives,   bonus, and etc., should be part of the payroll system. 

    All benefits and allowances such as meals, housing, uniforms, etc., should be included. All  deductions such as social security (medical and  pension), taxes, loans, and etc., should also be  included.
                 

    If the factory is not equipped for an organized or  automated payroll system, a commercial payroll service, if available, is an acceptable alternative.

    For piece rate and/or quota payments, employee sign-off  sheets should be available confirming the correct unit counts. The employee should sign off on any   random re-counts that are used for  verification.
                       

    Since accurate payroll calculations are based on the  time that the factory workers work, an accurate  time recording device such as an electric or electronic   time clock should be used. The time clock should be periodically checked for accuracy. Each worker  should have their own time card to record  time in and time out including meal breaks and rest   breaks.

    If an electronic recording device is used, each worker should have a worker identification card to   record time in/time out, meal breaks and rest  breaks. The factory should maintain a summary sheet listing the time worked for all the workers.
                       

    The factory should perform periodic reviews to determine  the accuracy for the method of paying the  workers. Mechanical and electronic equipment should be   checked to ensure that it is in proper   working order. If this equipment is found to be  inaccurate, or not in working order, corrective action should be taken, including adjustment of back wages, if  required, for the period of time when the equipment malfunctioned.

    Question 1.11 Does the factory produce and retain   payroll records to support  compensation, including the payment of overtime and the   deduction or required taxes?

    The factory should keep payroll records for at least one  year or longer if required by law. Payroll summaries should also be retained with the following  information:
    

    Name and identification number of each employee.
    Hourly, weekly, monthly rate or piece rate if  applicable.
    Payment of minimum wage.
    Gross pay.
    Net pay.
    Pay period.
    Payment date.
    Minimum wage.

    Question 1.12 Does the factory provide all employees  with pay information which details the current period's wage calculation?

    The factory should provide each worker with a pay stub  or some other form of documentation listing the details for the pay period involved. This   information should include, but not be limited to:
     Total hours worked including regular and overtime  hours.
     Gross wages including advances or loans.
     Calculation of overtime, quota incentive and piece  rate if applicable.
     Make up pay for piece rate under the minimum wage.
     Social Security, pension, savings.
     Other deductions including repayment of loans.
     Net Pay.
     The factory should periodically interview workers,  selected at random, to verify that they have examined a detailed pay record and that they understand   the calculation of their gross pay and net   pay. Any deviations from the established procedures are  to be corrected in a timely manner.
                       

    Question 1.13 Does the factory pay piece rate workers at  a rate equivalent to the minimum  wage required by law?
                       

    The factory must ensure that all workers earn the  minimum rate according to law. If a piece rate worker cannot make the standard, the factory must adjust  the standard of the wage rate so that the  workers wage will be equal to the legal minimum wage. 
                       

    The worker should be advised of this and the payroll records should reflect this adjustment.
                       

    Question 1.14 Does the factory ensure that the workers  do not work more hours per day  and per week than the legal limits, or the JCPenney standard?
                       

    There are times when it is necessary for a factory to  work overtime to meet production and delivery schedules. However, workers who work excessive hours   will loose efficiency and production will decrease. In addition, the injury rate will increase.

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

    In the event that there is no local or national law governing maximum working hours or current law is  in conflict with the JCPenney standard, then the  JCPenney standard will apply.
                       

    If the factory determines that it is necessary to work  more hours then allowed by law, they must obtain a waiver from the appropriate governing 
authority. This waiver must list the period time covered and the amount of hours to be worked. Workers   must be paid for extra overtime according  to local or national law.

    The department or individual responsible for payroll  must perform periodic time card reviews to  ensure the hours worked by employees (voluntarily or  involuntarily) in a given day, week or month do not exceed legal limits. If official waivers have been  issued, the limits of the waiver must not be exceeded.
                       

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

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

    The factory must have a policy that expressly prohibits  all forms of discrimination. The workers must be made aware of this policy.
                       

   HEALTH AND SAFETY
   

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

    The factory must provide a safe working environment for  the workers. The building must be in good repair with no safety hazards. Procedures should  include, but not be limited to:
    A plan for fire safety.
    Adequately equipped first aid kits.
    Easily accessible sanitary drinking water in work and   residential areas.
    Sanitary toilet facilities.
    Adequate ventilation throughout building and dormitory.
    Structurally sound and clean building facilities, including dormitories.
    Machinery and equipment that is safe and will not  cause injury to the workers.
    Emergency evacuation plans, in the native language(s)  of the employees, posted in view of  factory workers (i.e. a diagram of the factory layout   with emergency exits and routes highlighted).

    The factory should maintain inspection records and  operating permits for building and equipment as required by law. This should include, but not be limited   to:
    Inspection certificates and citations issued by  government agencies.
    Operating permits issued by government agencies.
    Health and safety reports detailing findings, recommendations and corrective actions.
    Machinery inspection and maintenance reports issued by  factory management.
    Fire extinguisher inspection records noting dates  inspected and expiration.
    Records of fire safety drills including the dates held  and any pertinent details on the results of the drills.
    Work injury reports including the nature and frequency  of accidents.
    Clinic logs listing the reason for visit.
    The factory should comply with all local and national  government health requirements. Records and correspondence should be maintained for any on site
inspections. Deficiencies discovered during these inspections should be recorded. The factory should   correct all deficiencies and notify the
 appropriate government agency for a re-inspection. 
    Records should be maintained of the reinspection.
    Once the factory passes the re-inspection, all  documentation should be kept as evidence  of the passed inspection.

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

    The factory should have procedures in place for the safe   operation and use of machinery and  equipment. This should include the handling, use and 
storage of chemicals. These procedures should include, but not be limited to:
    

    Machinery and equipment safety:
    Training workers in the safe use of machinery and equipment.
    Providing appropriate personal protective equipment, free of charge, to factory workers and  requiring them to use it. This equipment includes:
    

    Respiratory protection
    Skin protection
    Eye and face protection
    Hearing protection
    Foot protection
    Hand protection
    Head protection
    Providing appropriate safety guards and features on all  machinery and equipment and ensuring that  they are functioning properly.

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

    Ensuring that boilers have operational pressure release   valves.
     

    Chemical safety:
    Ensuring proper storage of hazardous and toxic materials.
    Providing periodic physical exams for workers handling hazardous materials.
     Training workers in chemical safety.
     The factory should perform the following functions to  ensure that the workers are performing under  the safest conditions possible:
     

   Periodically review all safety procedures to ensure that  they are adequate and being followed by the  workers.
    Develop programs and materials to train workers and  managers on procedures for machinery and equipment and chemical safety.
    Train the workers on the use of personal protective  equipment and safety guards. This equipment should be accessible and the workers should be required  to use it.
     

    Store hazardous or toxic materials properly.
    Continually inspect equipment and machinery to ensure  proper operation of required safety features and that the workers using this equipment are properly  trained.

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

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

    Question 2.3 Has the Factory implemented procedures for  fire safety which include worker housing and dormitories?

   Fire safety is extremely important. The factory should  have procedures in place that will ensure the workers are protected against fire and fire related  hazards. This should include worker housing.
    

    The building and/or dormitory should have fire  extinguishers placed in every room. A fire extinguisher  should be placed within 50 feet of each worker, and be  of an appropriate size that can be handled by  the average worker. The type of fire extinguisher used  depends upon the type of fire. For example, an area that uses electrical equipment will need a  different type of fire extinguisher than an area  where chemicals are used. All workers should be trained   in the proper use of fire extinguishers. In  addition, selected workers should receive extensive fire  training and be organized as a fire fighting  brigade. Fire extinguishers are intended for spot fires  which are usually small fires. These fires can  start by spontaneous combustion, defective or  overheating machinery and equipment, careless smoking or other causes. Sprinkler systems, fire hoses   or other fire fighting devices are intended for  large fires, but should not replace fire extinguishers. 
                       

    Fire extinguishers should be serviced annually.
                       

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

    The building should have enough emergency exits to allow  the workers to leave the building in a fast and orderly manner. Exits should be on opposite sides of  the building. If the building is more than one story there should be sufficient stairways to allow  the workers to get to the ground floor and exit the building in a fast and orderly manner. A traditional  fire escape on the outside of the building is  preferred, however, any stairway that leads to the  ground floor and is near an exit to the outside is acceptable.
                       

    All exits should be clearly marked and accessible. Exits  must not be locked or blocked in any way. If building security or theft is a concern then push bars  should be used on the exit doors. This will prevent the door from being opened from the outside, but  allows the door to be easily opened from the inside in case of an emergency. For additional  security an alarm can be installed on the door to advise security personnel when it is opened.

    The factory should conduct periodic fire drills to  ensure that all workers know how to leave the building in a fast and orderly manner.
                       

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

    The factory should develop a fire evacuation plan. This  plan should clearly define the nearest exit  path and be prominently posted for the workers. For  large buildings, several evacuation plans should  be posted at different locations throughout the building.
                       

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

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

    FACILITY AND ENVIRONMENT
    Question 3.1 Is there sufficient work space for each   worker to perform their duties in a safe manner without interference from other workers,    machinery or equipment, and raw materials used in production?
                       

    The factory should be designed and operated in a manner  that will allow sufficient area for each  worker to perform their duties without interference from  other workers. This area should include  sufficient space for materials, tools and other items  that are necessary for manufacturing the product.
                       

    There should be sufficient room between workers to allow  them to leave their work area in a fast and  orderly manner in case of fire or other emergency. Each   work station should have adequate lighting  to reduce the risk of eye strain.
                       

    The factory should perform periodic inspections to  ensure that the condition of each work station is  safe and well lit. Any defective areas should be   repaired or replaced as required. Work station  inspection records and a corrective action procedure  should be maintained.