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“c) and d) of Verification requirements Part A” are needed to be clarified.

Is “c) and d) requirements” for manufacturer or suppliers to document it? If this is the requirement for suppliers, it is an excessive requirement.  Therefore the following c) and d) should be deleted.

 

“c) Where issues have been raised, document the process to identify relevant assessments carried out by industry-independent civil society organizations and other experts”

“d) Where issues have been raised, document the process for evaluating and addressing relevant inconsistencies between social audit findings and findings produced by industry-independent civil society organizations and other experts”

 

The terms of “issues” and “social audit” used in the c) and d) should be clarified as commented in 7.1.1. (“issues” should be changed to “assertions or allegations”, and “social audit” should be construed as social audits conducted to suppliers prior to the allegation, and the requirement d) shall be construed as imposed if the audit had been conducted prior to the allegation.)

 

“e) of Verification requirements Part A”

The supplier list is very sensitive to manufacturers and there seems to be a confusion about the difference between 7.1.3 and 7.1.4., so it should be clearly stated that the supplier list is not required to make public for evidence of the “Required” Part A of 7.1.3.

 

“e) List the name (i.e., legal or trade) and complete physical address of all supplier facilities in scope and those identified as Prioritized Supplier Facilities. This list should be updated annually.”

 

 

“c) and d) of Verification requirements, Part A” should be deleted.

 

If c) and d) remain requirements, the same clarification as mentioned at 7.1.1 should be made and stated.

“c) and d) in Verification requirements of Part A” should be deleted.

Or the “requirements of c) and d)” should be changed as follows:

 

c) Where [Delete: issues have been raised] [ADD: any assertions/allegations with well-documented evidences pertaining to supplier facilities’ failure to meet compliance of the provisions in Annex B from internationally well-known industry-independent civil society organizations are actually delivered to the supplier facilities within one year before the date of the product’s application,] document the process to identify relevant assessments [DELETE: carried out by industry-independent civil society organizations and other experts] [ADD: related to the assertions/allegations. ]

 

d) Where [DELETE: issues have been raised] [ADD: any assertions/allegations  with well-documented evidences pertaining to supplier facilities’ failure to meet compliance of the provisions in Annex B from internationally well-known industry-independent civil society organizations are actually delivered to the supplier facilities within one year before the date of the product’s application,] document the process for evaluating and addressing relevant inconsistencies between [DELETE: social audit findings and findings produced by industry-independent civil society organizations and other experts][ADD: the prior social audit findings and the assertions/allegations.]

 

The condition for the verification requirement should be added as follows:

[ADD: If no assertion/allegation with well-documented evidences pertaining to supplier facilities’ failure from internationally well-known industry-independent civil society organizations is actually delivered to the supplier facilities within one year before the date of the product’s application, c) and d) are not applicable. If suppliers had no social audit before the allegation, d) is not applicable.]

 

e) of Verification requirements should not be made public. The following text should be added:

“e) List the name (i.e., legal or trade) and complete physical address of all supplier facilities in scope and those identified as Prioritized Supplier Facilities. This list should be updated annually [ADD: and be submitted to the certification examination agency, but it is not necessary to be disclosed public.]