Principle 6 FAQs
These are common questions surrounding our recent updates to Principle 6. If you want to ask another question that is not shown here, click here to contact the compliance team 
 
What has changed?

WRAP has changed its certification criteria to allow factories that meet certain conditions to qualify for a standard, 1-year (Gold) certification, even if they are not yet in full compliance with limits on working hours set in local laws. Those conditions are:

1.Being fully transparent about their working hours;

2.Ensuring those hours are all being worked voluntarily, in conditions that protect worker safety and health;

3.Compensating all employees fully in accordance with WRAP’s Principle on Compensation and Benefits; and

4.Showing progress, from one audit to the next, toward meeting the working hour requirements in local law.

When do these changes take effect?

The new Principles came into effect on January 1, 2016.

Why is WRAP making these changes?

Our goal with making these changes are to achieve a greater level of transparency with the production facilities that we monitor so that we can drive more productive engagement with them to enable real and lasting improvements in working conditions. While many WRAP factories have consistently demonstrated a genuine desire to improve by being open and honest about their working hours with us, the numeric working hour requirement that defined our previous Principle 6 provided a rationale for some facilities to provide auditors with forged or inaccurate documents making it appear that they were in compliance with the law, when in actuality this was not the case. WRAP’s vision for its Certification Program is to use it as a vehicle toward meaningful improvements in working conditions in the sewn products sector, and the essential first step toward this goal is honesty and transparency from all facilities.

Are other Principles being changed?

No, WRAP’s other 11 Principles, and the expectation of full compliance with them, has not changed. All WRAP facilities are still expected to remain in compliance with these Principles.

How will this change the audit cycle?

Initially, these changes will have little effect on the actual audit process itself as working hours will be evaluated as normal. Moving forward for future audit cycles however, facilities that are issued Working Hours Action Plans (WHAP) will be expected to demonstrate that adequate progress has been made toward their WHAP during each successive audit until the facility comes into compliance and that they meet the following conditions:

1. The facility is fully transparent about their working hours;

2. The facility ensures that all hours are being worked voluntarily, in conditions that protect worker safety and health;

3. That all employees are compensated fully in accordance with WRAP Principle 5.

What is a WHAP (Working Hours Action Plan)?

A WHAP (Working Hours Action Plan) is a roadmap document that outlines an actionable, verifiable plan for a production facility to gradually come into compliance with their country’s local working hour laws. WHAPs will be completed by the individual production facility, then submitted to the monitoring firm who will submit them to WRAP. WHAPs will be included in a facility’s audit file and they must also demonstrate that adequate progress is being made toward the WHAP during each successive audit.

What does this mean for new facilities?

Facilities that submit their first application for WRAP certification after January 1, 2016 will undergo a normal certification audit to determine their compliance with all of WRAP's 12 Principles. During the audit, the facility's working hours will be assessed for compliance with the law. If the facility’s working hours are found to not be in compliance with local law, but the facility otherwise qualifies for a Gold certification, WRAP will engage with the facility to complete a Working Hours Action Plan (WHAP) that outlines a path to compliance.

What does this mean for existing facilities?

For facilities with current WRAP certifications, working hours will be evaluated at the first audit, including PCA audits, that takes place after January 1, 2016. If the facility holds a Gold or Platinum certificate, or if it holds a Silver certificate and the audit finds that it otherwise qualifies for a Gold certificate, WRAP will work with the facility to create a Working Hours Action Plan (WHAP). Please note that Platinum facilities who are issued a WHAP will lose eligibility for Platinum as long as the WHAP is in place.

I heard that this change was motivated by some facilities in China. Will the new rules apply only to Chinese facilities?

No, these new rules will apply to all WRAP facilities around the world.