Do you know just how many quality controls we use within our Certification Program? Just like other players in the social compliance world, we are constantly focused on ensuring that our facilities maintain sustainable compliance practices and that the integrity and skill of our internal and third party monitors is upheld. Our certificate is not just a piece of paper or recognition to obtain in the short term; it is a mark of achievement for successfully adopting high social responsibility practices and also a commitment to maintain them for as long as they continue to be in operation. Once a factory is in the WRAP Program, they are dedicated to upholding all 12 of the WRAP Principles. It is our hope that a factory’s motivation to maintain minimum standards and promote their workforce’s wellbeing is rooted deeply in the way they conduct business. However, we know that this may not always be the case and thus we have our own internal checks.
Each year, WRAP re-visits about 20% of the total factories certified in that year at no cost to the factory. Half of these Post Certification Audits (PCAs) are conducted by our third party monitoring partners, while the rest are conducted by our own internal auditors. WRAP staff and the Review Board work proactively to manage factories that are at a high risk of lapsing back into bad practices. We base the risk off of factors like location, previous violations, and history with WRAP.
In 2014, WRAP revisited over 300 of our certified factories. Twenty percent of these factories passed the PCA with no violations, while forty percent had minor non-compliances which we later closed through an offsite audit which we call a ‘desktop review.’ These desktop reviews are an efficient, economical way of ensuring the facility has taken proper, corrective action without having to spend the time and resources on making an onsite audit. Desktop reviews are to be utilized only when the non-compliance is not a result of a major management systems failure. Thirty percent of the factories inspected post-certification had major findings raised or denied full access to the auditor. The remaining facilities had either moved, shut down, or were temporarily closed due to low orders.
Embedded in the mission of WRAP is a desire to work with factories and encourage them to constantly improve themselves, the quality of their management systems, and the wellbeing of their workers. Throughout the PCA process, we give factories ample opportunities to engage with us to remediate any non-compliances found (as described further in the next paragraph). However, there are some facilities that choose not to fully cooperate with this process. For cases like these, we suspend (or decertify) the facility’s certificate for a period of twelve months and inform the factory’s buyers of our decision. We would also decertify any factory where we find extremely serious violations (such as child or forced labor) or any attempt to bribe or threaten harm to our auditors.
In the cases where major findings were raised, WRAP issues the factory an Alternative –to-Decertification offer giving them the opportunity to take proper remediation. This means that the factory must prove they have corrected the non-compliances and send evidence of such to the relevant auditing team, pay for a follow-up audit and then pass the follow-up in order to avoid decertification. If the facility has not closed all of the non-compliances, they are decertified. At this point, it becomes clear to us that the facility is not serious about maintaining compliance, implementing sustainable and effective internal management systems, continuously improving, or actively participating in the WRAP process, especially after we have offered ample time and opportunities to remediate.
These quality control measures increase the value in our program because they allow for greater confidence in our factories and thus boost the credibility of our certificate. By enforcing warranted consequences on factories, auditors, and auditing firms, we make a stand for the mission of WRAP and make clear that we are serious about our goals to promote safe, lawful, humane and ethical manufacturing around the world.