Housing – is the producer responsible for unmade beds, dirty dishes, or other hygiene matters inside an occupant’s house?
If a business offers accommodation to its workers, certain legislative requirements are applicable to that business, and also certain compliance criteria will be measured. The “state of the occupants living arrangements” is not regulated by law, although businesses often have accommodation rules or housing agreements in place that stipulate what the occupants’ responsibilities are. As part of the audit, the auditor will evaluate the structural, safety and hygiene of the accommodation. This does not include whether the bed has been made or whether the occupant washed their dishes or not. There are, however, clear hygiene risks that could be applicable. For example, if the auditor can see waste in or at the house, it could cause a health risk. Auditors will evaluate the risks to the occupants, and also the risks to the business. If a fire risk exists at the house, then the owner of the property is responsible for ensuring it is implemented. Naturally, the housing agreement may also place a responsibility on the occupant to maintain it, or if damaged, the replacement cost can be deducted. During an audit, the auditor will also look at any maintenance conducted by the business over the last year, especially in the last 6 months (if applicable), to determine whether a finding is justifiable or not.
What is the producers’ responsibility towards houses that are occupied by non-employed workers?
The accommodation facility/building is the property of the owner. If occupants reside on the premises, whether it be illegally or due to pending court orders, the structural safety of the building remains the owners’ responsibility. The auditor will evaluate the risk to the farm on the day by determining whether these accommodation facilities pose a risk. If producers are not maintaining the buildings, and there is no reason for doing so, then it’s likely that a finding will be raised if the facilities pose a risk. Remember that if accommodation is subject to employment, and the employee leaves the employment, the business must follow through on the notice to vacate. If the occupants are illegally staying on the farm, the business can follow legal procedures to assist with a formal eviction unless the occupants are residing legally if they meet requirements set out by the Extension of Tenure and Security Act (ESTA).
How is the business protected when auditors conduct anonymous interviews with workers and one worker has a grudge against a manager/owner? Is this being reported on during the audit?
The auditor cannot raise a finding based on the comment of only one worker unless they were able to triangulate the evidence or found substantiating evidence through more interviews. The auditor will need to look at documentary evidence such as grievance records, complaints raised by worker committees, etc., and interview more workers to determine whether this was an isolated case, possibly untrue or whether it was shared by other workers as well.
Can my buyers see my findings after my audit, even if I have not yet submitted corrective actions?
It is a market requirement that the signed Corrective Action Report should be available within 24 hours after an audit. Once an audit has been conducted, the auditor loads the various findings on the platform, which allows the CAPS report (Corrective Action Plan) to be shared during the closing meeting. At this stage, the audit is still in progress, meaning the auditor will need to finalise the full report and send it for review at the audit firm. Only once the full report has been reviewed and approved will the buyers have access and visibility to the full audit report. The buyers, whether it be your local supermarkets, exporters, importers or global retailers, will most likely ask you to share the CAP report received on the day following the audit. This is because the buyers need to always have visibility on the supplier’s compliance status. Not only is this part of overall risk management, but it is often a need because of certain Due Diligence directives that buyers must meet globally. The SIZA programme does not provide an Audit Completion Letter until all the corrective actions have been submitted by the producer and closed out by the auditor. Therefore, once a producer receives the Audit Completion Letter, it is a testament to the process being completed in full and the improvement that has taken place.
In cases where a critical finding was raised, SIZA is bound by its market acceptance to share the risk with the buyers that are linked to the profile or the supplier. Although SIZA will notify the buyer, SIZA will also manage the risk by confirming with the buyer whether the necessary actions have already been taken to correct and manage the risk according to an agreement with the supplier, and in most cases their first-level export company.
It is not at all SIZA’s intention to damage or harm the value chain, but rather to secure a sustainable environment to supply with integrity, ethical and sustainable practices in place.