GLOBALGAP Risk Assessment on Social Practices (GRASP) Checklist GRASP Assessment Result from the GRASP Project Document for public review until 26 March 2010 V 2.0 Feb 2010 English Version Producer: Signature: Certification Body: Assessor: Signature:
How to use this document This checklist provides shall be used by assessors who are assessing the implementation of the GRASP Module on farms. GRASP is the Abbreviation for GLOBALGAP Risk Assessment on Social Practice. After the assessment, the filled checklist shall be uploaded to the GLOBALGAP database. Requirements for GRASP - Assessors The GRASP assessment can only be conducted by those GLOBALGAP approved auditors who participated in a GRASP Training for Auditors and who successfully completed the GRASP online training. An updated list of approved GRASP auditors can be obtained on the GLO- BALGAP website. Please consult about the next GRASP training for auditors in your region with the GLOBALGAP Secretariat. Requirements for Producers GRASP is a voluntary add-on module and does not form part of the accredited GLOBALGAP certification. However it logically complements the GLOBALGAP IFA and plant propagation material standards regarding issues of good social practice. Thus only producer / producer groups who are GLOBALGAP certified (or in the process of achieving a certificate) can register for a GRASP Assessment. How to report on the GRASP - Assessment Compliance to the control points is voluntary and has no influence on the GLOBALGAP certification. However, if a producer decides to conduct the assessment, the upload of the filled checklist(s) to the GLOBALGAP database is mandatory. After the assessment, please provide two copies of the filled and sigend checklist to the producer (the farm management and the employees representative) and keep the original as a proof of assessment. If farm management does not want to sign the Assessment checklist, explain why. The results of the assessment will then be visible through the GLOBALGAP database (proof of assessment) according to the data use agreement signed by the producer in the sub-license agreement. Local interpretation Legal requirements regarding the control points differ from country to country (e.g. minimum wage, age of legal employment, working hours etc.). Legislation overrides GRASP where relevant legislation is more demanding. Where there is no legislation (or legislation is not so strict), GRASP provides a minimum compliance criteria. No matter what the required compliance criteria is in GRASP, any applicable legislation that is stricter than GRASP must be complied with in the country where the producer is operating. In order to make those requirements transparent to producers and assessors, National Interpretations of the GRASP Module are developed in a process of stakeholder participation. The GRASP Module can only be assessed in those countries for which a National Interpretation is available. Consult the GLOBAL- GAP website on the available Interpretations. And see further details in the GRASP General Regulations How to fill the checklist The GRASP control points are formulated in a complex way, often covering more than one aspect. In order to make the requirements clearly understandable, this checklist shall be used to assess each control point. Therefore each control point is structured into sub-points that give an orientation to the assessor. With these subpoints, the (minimal) means of verification are provided. In the last column, the assessor is required to comment on compliance of each sub-point (Yes / No / nonapplicable). The final decision on compliance is taken on the aggregated level of the control point. Below each control point, remarks shall be given. However, remember that as an assessor, you are not allowed to provide consultancy to the producer you or your company is assessing. Within this assessment checklist, remarks in italic provide you with assessment instructions and cross-references. Assessment Techniques: Summary For assessing social issues, a special sensitivity of the assessor is required. Please consider the following points when you assess the GRASP Module Prepare well for the assessment. You must be aware of up-to-date information regarding legal regulations, bargaining agreements etc. The National Interpretation supports your preparation. Do also read the Implementation Guideline. If you are assessing GLOBALGAP on the same day, do not start with the GRASP Module, but rather do it towards the end of the audit. It is much easier to target social issues with an established level of confidence. Do not necessarily stick to the order provided in the checklist, but find a logical sequence according to the situation. Start with rather uncritical issues and documents checks and then move to the more sensitive topics. Especially during the interview with the employees representative, make sure that he/she is in an environment where he/she can openly talk without farm management being present. Do give attention to a good atmosphere between you and the persons you talk to. If persons feel controlled or negatively judged by you, it is likely that you will not be told everything. Observe your non-verbal communication (facial expression, gestures etc). Do not inspect the farm with a checklist in front of your face. For assessing the control points, it is crucial that you know them by heart. If you feel that you may not be told the truth, do not insist. Find other ways of clarifying the issue, by checking more documents, talking to a different person or simply by rephrasing your question in a later stage. GRASP Assessment 2
Example: Sub-points to be targeted during the assessment Here, the (minimal) means of verification for each sub-point are Mark your findings here (Yes / No / not applicable Tick here to give your overall judgement on compliance Space for general remarks and comments on improvements needed. Must be completed in the case of a nonapplicable in a sub-control point. Please fill if applicable. Legend: Record Verification Site inspection Question to the Farm Manager Question to the responsible Person for workers health, safety and good social practice Question to the Employee s Representative GRASP Assessment 3
1 Is there at least one employee or an employees council to represent the interests of the staff to the management? Documentation is available which demonstrates that a clearly identified, named employees representative and / or a employees council representing the interests of the employees to the management is elected or nominated by all employees and recognised by the management. This person shall be able to communicate complaints to the management without personal sanctions. The election/nomination of the representative(s) is documented. In case of a council, its composition is documented. In case of option 2 certification with high rotation of employed workforce, a producer (or other suitable person to execute this task) can be nominated on group level The election/nomination has taken place in the ongoing year or production period The representation is actual (all elected/nominated person(s) according to the list still work on the farm or in the group) The ER is/are aware of his/her/their role and rights. In case of a council, all members are interviewed. The ER ( s) know(s) he/she/ they can file complaints to the farmer without personal sanctions SUMMARY CONTROL POINT 1: Remarks / Improvements needed: GRASP Assessment 4
2 Is there a complaint procedure available on the farm, through which employees can make a complaint? A complaint procedure exists on the farm, the employees have been made aware of its existence and complaints or suggestions can be made at any time without personal sanctions. The complaint procedure specifies a time frame to resolve complaints. Complaints and their solutions from the last 24 months are documented and accessible. A documented complaint procedure is available, appropriate to the size of the farm Through the complaint procedure, complaints can be made by employees at any time without personal sanctions The complaint procedure sets a time frame to resolve complaints (e.g. during the next month) The complaints and their follow-up are documented and available for the last 24 months SUMMARY CONTROL POINT 2: GRASP Assessment 5
3 Has a self-declaration on good social practice regarding human rights been communicated to the employees and signed by the farm management and the employees representative? The farm management and the employees representative have signed and displayed a self-declaration assuring good social practice and human rights of all employees. This declaration contains at least commitment to the ILO core labour conventions (ILO Conventions 111 on discrimination, 138 and 182 on minimum age and child labour, 29 and 105 on forced labour, 87 on freedom of association, 98 on the right to organize and collective bargaining, 100 on equal remuneration and 99 on minimum wage) and transparent and non-discriminative hiring procedures. The self-declaration has been actively communicated to all employees and is at least revised every 5 years. The declaration is complete and contains at least all points referred to in the compliance criteria The declaration has been signed by the farm management and by the employee s representative( s) The declaration is actively communicated to the workers (e.g. displayed on the farm or attached to every working contract, information meetings etc.) The declaration has been handed out to the responsible person for workers health, safety and good social practice (GSPR) The declaration has been handed out to the employees representative( s) (ER) The farm management and the employee s representative( s) know the content of the declaration and confirm that it is put into practice The declaration is checked and revised at least every 3 years or whenever necessary SUMMARY CONTROL POINT 3: GRASP Assessment 6
4 Do the person responsible for workers health, safety and good social practice and the employees representative(s) have knowledge about and/or access to recent national labour regulations? The responsible person and the employees representative(s) demonstrate awareness and access to national regulations concerning: gross and minimum wages, working hours, union membership, anti-discrimination, child labour, labour contracts, holiday and maternity leave, medical care and pension/gratuity. GSPR and ER have knowledge about valid labour regulations on gross and minimum wages GSPR and ER have knowledge about valid labour regulations on working hours GSPR and ER have knowledge about valid labour regulations on union membership GSPR and ER have knowledge about valid labour regulations on anti-discrimination GSPR and ER have knowledge about valid labour regulations on child labour and minimum age of working GSPR and ER have knowledge about valid labour regulations on labour contracts GSPR and ER have knowledge about valid labour regulations on holiday and maternity leave GSPR and ER have knowledge about valid labour regulations on medical care and pension/gratuity Check 3-5 points on a risk-base, according to the region and your personal impression of the farm SUMMARY CONTROL POINT 4: GRASP Assessment 7
5 Can copies of working contracts be shown for every employee? Do they indicate at least full names, a job description, date of birth, date of entry, wage and the period of employment? Have they been signed by both the employee and the employer? For every employee, a contract can be shown to the assessor on request. Both the employee as well as the employer have signed them. Records contain at least full names, nationality, a job description, date of birth, the regular working time, wage and the period of employment. Records of all employees (also subcontractors) must be accessible for at least 24 months. Random checks show that for all employees, a copy of their contract can be shown The working contracts include at least basic information on the employee s name and nationality The working contracts include at least basic information on the contract period (e.g. permanent, day labour etc.) The working contracts include at least a basic job description The working contracts include information on working hours & breaks SUMMARY CONTROL POINT 5: Remarks / Improvements needed: GRASP Assessment 8
6 Do records indicate that no minors are employed on the farm? Records indicate compliance with national legislation regarding minimum age of employment. If not covered by national legislation, children below the age of 15 are not employed. If children -as core family members- are working on the farm, they are not engaged in work that is dangerous to their health and safety or that jeopardizes their development. Dates of birth on the records show that no employee is aged below minimum age of employment (or under 15 if no such national legislation exists) If children -as core family members- are working on the farm, they are not engaged in work that is dangerous to their health and safety or that jeopardizes their development SUMMARY CONTROL POINT 6: Remarks / Improvements needed: GRASP Assessment 9
7 Do all children living on the farm have access to compulsory school education? There is documented evidence that all children at compulsory schooling age (according to national legislation) living on the farm have access to compulsory school education, either through provided transport to a public school or through adequate on-site schooling. There is a list of children in the age of compulsory schooling age living on the farm, with sufficient indications on name, name of parents, date of birth, school attendance etc. There is evidence of transport facilities if children cannot reach school within half an hour walking There is evidence of an appropriate on-site schooling system when access to schools is not available SUMMARY CONTROL POINT 7: GRASP Assessment 10
8 Is there a time recording system that shows daily working time and overtime on a daily basis for all employees? There is a time recording system that makes working hours and overtime transparent for both employees and employer on a daily basis. Working times of all employees during the last 24 months are documented. A time recording system is implemented, appropriate to the size of the farm (e.g. time record sheet, check clock, electronic cards etc.) The records indicate the regular working time for every employee on a daily base The records indicate the overtime hours for every employee on a daily base The records indicate the breaks / festive days for every employee (on a daily base) The working records are regularly approved by every employee (e.g. regularly signed record sheet, checking clock) Access to these records is provided to the Employees Representative(s) The records are kept for at least 24 months SUMMARY CONTROL POINT 8: GRASP Assessment 11
9 Do working hours and breaks documented in the time records comply with applicant legislation and/or collective bargaining agreements? Documented working hours, breaks and rest days are in line with applicant legislation and/or collective bargaining agreements. If not regulated by legislation, records indicate that regular weekly working hours do not exceed 48 hours, during peak season (harvest), weekly working time does not exceed 60 hours. Rest breaks/days are also guaranteed during peak season. Information on valid labour regulation and/or collective bargaining agreements is available/accessible, referring to working hours and breaks Working hours including overtime as shown in the records indicate compliance with legal regulations and/or collective bargaining agreements Rest breaks / days as shown in the records indicate compliance with national regulations and / or bargaining agreements If not regulated differently by applicant legislation, regular weekly working time does not exceed 48 hours. During peak season (harvest), weekly working time does not exceed 60 hours The records indicate that rest breaks/days are also guaranteed during peak season SUMMARY CONTROL POINT 9: GRASP Assessment 12
10 Is there documented evidence indicating regular payment of salaries corresponding to the contract clause? The employer shows adequate documentation of the salary transfer (e.g. employee s signature on payslip, bank transfer). All employees sign or receive copies of payslips / pay register that make the payment transparent and comprehensible for them. Regular payment of all employees during the last 24 months is documented. Documented evidence (e.g. payslips or pay registers) is available for all employees (Random checks) Payslips or pay registers indicate that payments are made at regular and defined intervals and without delay Payslips or pay registers indicate that payments are made in accordance with the working contracts and working time records Documents indicate that the salary transfers to the employees are made adequately in accordance with the contract (e.g. worker s signature on payslips, bank transfer etc.) The record of payments are kept for at least 24 months SUMMARY CONTROL POINT 10: GRASP Assessment 13
11 Do payslips / pay registers indicate the conformity of payment with at least legal regulations and/or collective bargaining agreements? Wages and overtime payment documented on the payslips / pay registers indicate compliance with legal regulations (minimum wages) and/or collective bargaining agreements (if applicable). If payment is calculated per unit, employees shall be able to gain at least the legal minimum wage (on average) within regular working hours. Payslips or pay registers give clear indication on the number of compensated working time or harvested amount (hours/days) including overtime Wages and overtime payments as shown in the records indicate compliance with national labour regulations and/or collective bargaining agreements Independently from the calculation unit, payslips / pay registers document that employees gain in average at least the legal minimum wage within regular working times (especially check when piece-rate is implemented). If there are deductions from salary for employees getting paid below minimum wage these deductions must be justified. SUMMARY CONTROL POINT 11: Remarks / Improvements needed: GRASP Assessment 14
N Control Point and Compliance Criteria Verification 12 What other forms of social benefit does the employer offer to workers, their families and/or the community? Please specify in quantities if possible. There are incentives for good and safe working performance Bonus payments exist in certain cases A support for the professional development of employees exists Family friendly measures have been taken on the farm There are additional measures taken in the field of medical care and health provision There are additional measures taken to improve the social surroundings of the farm CONTROL POINT 12: Description / GRASP Assessment 15
ONLY APPLICABLE FOR PRODUCER GROUPS N Control Point and Compliance Criteria Verification Compliance 13 Does the assessment of the Quality Management System of the Group show evidence of the correct implementation of GRASP for all producer group members? The assessment of the Quality Management System of the producer group demonstrates that GRASP is correctly implemented, internally assessed and that actions are taken to enable compliance of all producer group members. Is the implementation of GRASP included in the Quality Management System of the producer group based on the GLOBALGAP IFA GR v3.1nov09 Part III for producer group certification? Is there a system in place to demonstrate that key staff is informed and is aware of development, issues and legislative changes relevant to the compliance to GRASP? Does all documentation relevant to the operation of the QMS for GRASP compliance exist and is it adequately controlled? Is there a register maintained of all GLOBALGAP (EUREPGAP) member producers that are implementing GRASP? Does the register contain the Internal inspection date for every producer member? Are records of the internal assessment plan, assessment findings and follow up of corrective actions resulting from an assessment maintained and available? SUMMARY CONTROL POINT 13: GRASP Assessment 16
Proposal for additional Control Points collected during 2008/2009 for public consultation: N Control Point and Compliance Criteria Verification Compliance NEW Do records indicate that all non-national employees have a legal status allowing them to legally work on the farm? Records indicate that all non-national employees have a legal status / working permit to be legally employed on the farm, according to national legislation Records indicate the nationality of all employees. The self-declaration on good social practice ensures that hiring procedures of employees are fair and transparent, not discriminating anyone on the basis of race, caste, nationality, religion, handicaps, sex, sexual orientation, maternity, age, political views, membership of a trade union or political party. If non-national employees are working on the farm, records indicate their legal status for being employed on the farm. SUMMARY CONTROL POINT: GRASP Assessment 17