WRAP Audit and Compliance

WRAP Audit and Compliance is an excellent topic that sits at the intersection of corporate social responsibility, international trade, and supply chain management.

Let’s break down the concepts of “Auditing Schemes and Programs to International Standards” and then focus specifically on the WRAP Audit and Compliance program.

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Part 1: Auditing Schemes and Programs to International Standards

In the context of supply chains and manufacturing, this refers to independent verification systems that check if a factory’s practices align with globally recognized benchmarks for quality, safety, ethics, and sustainability.

Key Concepts:

• Auditing Scheme/Program: A structured system with a specific set of principles, rules, and procedures for conducting audits. Examples include WRAP, SMETA, BSCI, and ISO-based certification schemes.
• International Standards: The established benchmarks against which a facility is measured. These are often developed by international bodies and are based on:
  • International Labour Organization (ILO) Conventions: Core labor standards like freedom of association, no forced labor, no child labor, no discrimination.
  • Local Laws: Compliance with the national and local laws of the country where the factory operates.
  • Environmental & Safety Protocols: Standards for waste management, chemical handling, workplace safety (e.g., ISO 14001 for Environment, OHSAS 18001/ISO 45001 for Safety).

Why Are These Schemes Important?

1. Risk Mitigation: Brands use them to identify and avoid suppliers with poor labor practices, which can lead to reputational damage, legal issues, and supply chain disruptions.
2. Brand Reputation & Consumer Trust: Demonstrates a commitment to ethical production, which is increasingly important to consumers.
3. Supply Chain Transparency: Provides a clear, verified view of working conditions deep within the supply chain.
4. Efficiency for Suppliers: Instead of facing dozens of different audits from different brands, a supplier can get one certification (like WRAP) that is accepted by many buyers.
5. Continuous Improvement: These programs are not just about pass/fail; they often provide a framework for factories to systematically improve their operations.

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Part 2: Deep Dive into WRAP Audit and Compliance

WRAP stands for Worldwide Responsible Accredited Production. It is one of the world’s largest independent factory certification programs focused on the apparel, footwear, and sewn products sectors.

What is WRAP?

WRAP is a non-profit organization that provides a comprehensive and independent certification program to ensure that sewn products are made under lawful, humane, and ethical conditions. Its core philosophy is based on a 12-principle framework.

The 12 WRAP Principles

These principles are the “international standards” against which a WRAP audit is conducted. They are grouped into three categories:

A. Compliance with Laws and Workplace Regulations

1. Compliance with Laws and Workplace Regulations: Facilities must comply with the laws and regulations of their jurisdiction.
2. Prohibition of Forced Labor: No use of forced, prison, indentured, or bonded labor.
3. Prohibition of Child Labor: No employment of children under 15 (or the age for completing compulsory education, whichever is higher).
4. Prohibition of Harassment or Abuse: A workplace free from harsh or inhumane treatment.

B. Respect for Workers and Their Rights
5. Compensation and Benefits: Wages and benefits must comply with all applicable laws.
6. Hours of Work: Work hours must comply with laws and not exceed local limits for regular and overtime hours.
7. Prohibition of Discrimination: No discrimination based on race, gender, religion, etc.
8. Health and Safety: A safe and healthy work environment must be provided.
9. Freedom of Association and Collective Bargaining: Respect for workers’ rights to associate freely and bargain collectively.

C. Conformance with Customs and Export Laws & Environmental Requirements
10. Customs Compliance: Compliance with applicable customs laws, particularly regarding illegal transshipment.
11. Security: Facilities must implement security measures to prevent unauthorized shipments (e.g., drugs, explosives).
12. Environment: Compliance with applicable environmental rules, regulations, and standards.

The WRAP Audit and Certification Process

1. Self-Assessment: The facility conducts a thorough internal review against the 12 Principles and corrects any deficiencies.
2. Application: The facility submits an application to WRAP.
3. Audit Selection: WRAP assigns an independent, WRAP-accredited monitoring firm to conduct the audit.
4. On-Site Audit: The audit firm conducts a comprehensive, unannounced (or semi-announced) audit. This includes:
   • Document review (payroll, time records, policies)
   • Facility inspection (safety, cleanliness, machinery)
   • Confidential worker interviews
5. Corrective Action Plan (CAP): If any non-conformities are found, the facility must develop and implement a CAP to address them.
6. Evaluation & Certification: The audit report and CAP are reviewed by the WRAP Certification Board. If all requirements are met, a certificate is issued.

WRAP Certification Levels

WRAP understands that achieving full compliance is a journey and offers three levels of certification:

• “A” Platinum Certificate (6-Year Term): Awarded to facilities that demonstrate full compliance with all 12 Principles for three consecutive certification cycles (2 years each). This is WRAP’s highest honor.
• “B” Gold Certificate (2-Year Term): Awarded to facilities that demonstrate full compliance with all 12 Principles at the time of the audit.
• “C” Silver Certificate (1-Year Term): Awarded to facilities that demonstrate substantial compliance but have minor, non-systemic non-compliances. They must show they are working towards “B” or “A” level.

WRAP vs. Other International Schemes (A Quick Comparison)

Feature	WRAP	SMETA (Sedex)	BSCI (Amfori)
Focus	Factory certification for apparel/footwear.	Audit methodology and reporting format for any sector.	A initiative for retailers, importers, and brands to improve conditions.
Outcome	A certificate (Platinum, Gold, Silver).	An audit report (no certificate).	A report with a rating (A-B-C, etc.).
Philosophy	Holistic, principles-based certification.	A methodology to share audit data (via the Sedex platform).	A continuous improvement system managed by the brand.
Ideal For	Factories seeking a recognized certificate to attract buyers.	Brands/suppliers wanting a shared, transparent audit to reduce duplication.	Brands that want to manage their suppliers’ progress within a structured program.

Conclusion

Auditing Schemes like WRAP are critical tools for bringing international labor and ethical standards into practical, on-the-ground practice. They provide a structured, credible, and consistent way for brands to ensure responsible sourcing and for factories to demonstrate their commitment to ethical operations.

WRAP, in particular, stands out for its clear 12-principle framework, its focus on the sewn products sector, and its tiered certification system that rewards long-term excellence and encourages continuous improvement. For a factory, achieving a WRAP certification, especially a Platinum one, is a powerful market differentiator.

What is Required WRAP Audit and Compliance

The phrase “Required Auditing Schemes and Programs to International Standards – WRAP Audit and Compliance” refers to the mandatory systems and processes that a factory must implement and adhere to in order to successfully achieve and maintain certification against the international WRAP standard.

Let’s break this down into two parts: what is “required” and how it relates to the WRAP program.

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Part 1: The “Required” Elements (The Foundation)

Before a factory can even think about a WRAP audit, it must have certain schemes and programs in place. These are the formal, documented systems that ensure day-to-day operations meet the WRAP principles. They are “required” because without them, the factory will fail the audit.

Think of these as the building blocks of compliance.

1. Required Management Systems & Programs:

• Social Compliance Management System: A top-level program where management defines its ethical policy, sets objectives, and assigns responsibility for implementation.
• Human Resources (HR) Program: Must include:
  • Recruitment & Hiring Procedures: Ensuring no discrimination, verification of age documents to prevent child labor, and clear contracts.
  • Compensation Program: A system for accurately tracking working hours (overtime included) and calculating wages that meet or exceed legal minimums and overtime premiums.
  • Disciplinary Procedures: A formal, documented policy that prohibits harassment, abuse, and corporal punishment.
• Health & Safety (EHS) Program: Must include:
  • Risk Assessments: Regular identification of workplace hazards.
  • Training Programs: For fire safety, machine operation, emergency evacuation, and chemical handling.
  • First Aid & Medical Care: Procedures and facilities for handling injuries.
  • Environment, Health & Safety (EHS) Committee: A team with worker representation that meets regularly to discuss safety issues.
• Environmental Management Program: Procedures for handling, storing, and disposing of chemical waste and other pollutants in compliance with local laws.
• Security Program: Procedures to control access to the facility and prevent tampering with shipments (to combat illegal transshipment).

2. Required Documentation & Records (The Proof):

These are the tangible outputs of the programs above. An auditor will demand to see them.

• Personnel Files: For all employees, with proof of age and signed contracts.
• Time & Payroll Records: At least 12 months of detailed time cards and corresponding payroll records to verify correct payment of wages and overtime.
• Attendance Records: To cross-reference with time cards and payroll.
• Health & Safety Records: Inspection reports, accident/incident logs, training attendance sheets, and fire drill reports.
• Permits & Licenses: All required business, fire, safety, and environmental permits must be current and valid.

3. Required Physical Conditions (The Facility):

The auditor will inspect the entire facility to verify that the programs and documents reflect reality.

• Safe Working Environment: Proper machine guards, clean and organized work areas, adequate lighting and ventilation.
• Emergency Preparedness: Clearly marked and unobstructed emergency exits, functional fire alarms and extinguishers, and well-stocked first-aid kits.
• Fair Treatment: Signs of a respectful environment (e.g., no signs of harassment or abuse).

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Part 2: How These Requirements Map to the WRAP Audit & Compliance

The “Required Schemes and Programs” are what you DO. The WRAP Audit is the VERIFICATION that you are doing it correctly. The International Standards are the RULES you must follow (the 12 WRAP Principles, based on ILO conventions and local law).

Here is the direct link between the requirements and the WRAP principles:

Required Program / System	Relevant WRAP Principle(s)	What the Auditor Checks
HR & Legal Compliance	1. Compliance with Laws	Are personnel files, business licenses, and permits in order?
Recruitment & HR Files	2. Forced Labor; 3. Child Labor	Are there verified age documents? Are contracts voluntary?
HR Policy & Training	4. Harassment & Abuse; 7. Discrimination	Is there a policy? Are workers aware of it? Is it enforced?
Time & Payroll System	5. Compensation; 6. Hours of Work	Do records prove correct payment for all regular and overtime hours?
Health & Safety Program	8. Health & Safety	Are risk assessments done? Are records of training and drills maintained? Is the facility safe?
Policy & Management Support	9. Freedom of Association	Does management respect the right to form associations? Is there an open-door policy?
Supply Chain & Security	10. Customs Compliance; 11. Security	Are there procedures to prevent illegal transshipment and contraband?
Environmental Program	12. Environment	Are there procedures for waste management? Is the facility compliant with environmental laws?

Summary

In essence, “Required Auditing Schemes and Programs to International Standards” for WRAP means:

“The mandatory, documented management systems, operational procedures, and accurate records that a factory must establish and maintain to prove its continuous compliance with the 12 WRAP Principles, which are themselves based on international labor and safety standards.”

The WRAP Audit is the rigorous, independent inspection that tests these required systems. Compliance is the ongoing state of operating within this framework, not just to pass an audit, but to run a responsible, ethical, and sustainable business.

Who is Required WRAP Audit and Compliance

The short answer is that the factory or production facility is the primary entity required to implement these schemes and programs to achieve WRAP audit and compliance.

However, the requirement is driven by other actors in the supply chain. Let’s break down the “who” in detail.

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Primary Entity Required to Comply: The Production Facility

The factory or manufacturing facility that produces the goods (specifically in apparel, footwear, and sewn products) is the one that must undergo the audit and implement the necessary programs.

• Their Goal: To obtain and maintain WRAP certification.
• Their Motivation: To be eligible for orders from major global brands and retailers that require WRAP certification as a condition of doing business.

Within the factory, responsibility is delegated to:

• Top/Senior Management: They are ultimately responsible for funding, supporting, and championing the compliance program. Without their commitment, the required systems will fail.
• Social Compliance Manager / HR Manager: Typically the person tasked with implementing and managing the day-to-day requirements—maintaining records, conducting internal audits, training staff, and preparing for the external WRAP audit.
• Health & Safety Officer: Responsible for implementing and documenting the health and safety programs.
• Payroll & Accounting Department: Responsible for maintaining accurate time and payroll records that are central to proving compliance.

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Who Requires the Factory to Do This? (The Drivers)

The factory doesn’t implement these complex systems in a vacuum. The requirement is imposed by other key players:

1. Global Brands and Retailers (The Buyers)

This is the most direct source of the requirement. Companies like adidas, Nike, Walmart, Gap, and many others require their suppliers to be WRAP-certified.

• Why they require it: To manage their supply chain risk, protect their brand reputation, ensure ethical sourcing, and meet their own Corporate Social Responsibility (CSR) commitments to consumers and investors.

2. Consumers and Investors

While they don’t issue a formal “requirement,” growing consumer and investor demand for ethically produced goods creates immense market pressure. Brands, in turn, push this requirement down onto their suppliers.

3. International Standards and Laws (The Framework)

The requirement is based on the framework of:

• WRAP’s 12 Principles: The specific international standard for the audit.
• Local National Laws: Factories are required to comply with their own country’s labor, safety, and environmental laws, which are a core part of the WRAP principles.
• International Labour Organization (ILO) Conventions: These form the basis for the international labor standards within WRAP’s principles.

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The Role of Other Key Parties in the Process

• WRAP (The Organization):
  • Role: Sets the standard (the 12 Principles), accredits independent audit firms, trains auditors, and issues the final certification.
  • They are the “referee,” not the one being required to comply.
• WRAP-Accredited Monitoring Firms (The Auditors):
  • Role: Independent third-party organizations that conduct the on-site audit at the factory. They assess the factory’s programs and records against the WRAP standard and report their findings.
  • They are the “assessors,” not the ones being required to comply.

Summary: The Chain of Requirement

The flow of responsibility and requirement can be visualized as a chain:

Consumer/Investor Demand
↓
Brands & Retailers (require certification from their suppliers)
↓
Production Facility (THE ENTITY REQUIRED TO COMPLY)
↓
Implements Required Programs & Undergoes Audit
↓
WRAP-Accredited Auditor (verifies compliance)
↓
WRAP Organization (issues certification)

In conclusion, when you ask “Who is required…?”, the direct answer is the factory or manufacturing facility. They are required by their clients (global brands) to implement the necessary auditing schemes and programs to achieve compliance with the international WRAP standard.

When is Required WRAP Audit and Compliance

The “Required Auditing Schemes and Programs to International Standards – WRAP Audit and Compliance” are not a one-time event but an ongoing, continuous cycle. The requirements are in effect at all times, but there are key temporal milestones.

Here’s a breakdown of when these requirements apply:

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1. Pre-Audit: The Implementation Phase (Ongoing & Before Application)

This is the most critical period for establishing the required schemes and programs.

• When: Months or even a year before the audit. A facility cannot create these systems overnight. They must be implemented, documented, and operational long enough to generate a history of compliance.
• Key Activities:
  • Developing Policies: Writing the HR, Health & Safety, and Environmental manuals.
  • Training Staff: Educating managers and workers on the new procedures.
  • Generating Records: Running payroll correctly, maintaining time records, conducting safety drills, and keeping these documents for at least the past 12 months. The auditor will expect to see a full year of compliant records.
  • Self-Assessment: The factory must conduct its own internal audit to find and fix gaps before applying for the WRAP audit.

> > This is when the foundational work happens. Without these programs already in place, a factory will fail the audit.

2. The Audit Period: The Verification Phase (Focused Point-in-Time)

This is when the factory’s programs are put to the test.

• When: During the on-site audit, which typically lasts 2-5 days. The audit itself is a snapshot, but it assesses the facility’s continuous performance.
• Key Activities:
  • The auditor reviews the previous 12 months of records (payroll, time cards, etc.) to verify that the required programs have been functioning correctly over time, not just last week.
  • They inspect the physical facility to see if the programs are being followed in practice.
  • They conduct confidential worker interviews to confirm that policies are understood and implemented.

3. Post-Audit: The Corrective Action & Maintenance Phase (Continuous)

The requirement to maintain these programs does not end when the auditor leaves.

• When: Immediately after the audit and for the entire certification period.
• Key Activities:
  • Corrective Action Plan (CAP): If the audit finds non-conformities, the factory must immediately use its management systems to address them within a set deadline.
  • Maintaining Compliance: To keep its certificate valid (whether Platinum, Gold, or Silver), the factory must continuously operate all its required programs. There should be no difference in practice between the week before an audit and any other week of the year.
  • Surveillance (for Platinum): Platinum-certified facilities are subject to unannounced surveillance visits at any time, meaning their programs must be audit-ready 365 days a year.

4. Recertification: The Renewal Phase (Cyclical)

WRAP certificates have expiration dates, forcing a renewal cycle.

• When:
  • Platinum (A): Every 6 years (with surveillance visits).
  • Gold (B): Every 2 years.
  • Silver (C): Every 1 year.
• Key Activities: The entire process repeats. The factory must demonstrate that it has maintained its required programs continuously since the last certification and is ready for a new full audit.

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Summary: Key Temporal Triggers

The requirement for these schemes and programs is mandatory:

When?	Trigger	Requirement
Continuously	Ongoing Operations	The facility must operate its social compliance programs every single day to ensure ethical production.
At Application	Decision to seek certification	The facility must affirm that all required programs are fully implemented and that it has completed a self-assessment.
During the Audit	Scheduled on-site visit	The facility must demonstrate and prove through documents, interviews, and inspection that its programs are effective and have been for at least 12 months.
After the Audit	Issuance of Corrective Action Plan	The facility must use its management systems to correct any identified deficiencies promptly.
For Surveillance	Unannounced Visit (Platinum)	The facility must be “audit-ready” at all times, with all programs functioning perfectly.
At Expiration	Recertification Deadline	The facility must prove it has maintained compliance throughout the certification cycle to renew.

In essence, the “when” is ALWAYS. The requirement is for a state of continuous compliance. The audit is merely a periodic verification point in that ongoing cycle. A factory that only implements these programs right before an audit will almost certainly fail, as the required documentation (like 12 months of payroll) will reveal the inconsistency.

Where is Required WRAP Audit and Compliance

The “Required Auditing Schemes and Programs to International Standards – WRAP Audit and Compliance” are implemented and verified in specific, tangible locations.

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Primary Location: The Production Facility

The core physical location is the factory or manufacturing facility where goods are produced. This is the “where” for both the implementation and the audit.

Within the facility, the requirements apply to every operational area, including:

• Production Floors: Where sewing, cutting, and assembly happen. This is checked for safety, working conditions, and hours.
• Warehouses & Storage Areas: For material storage, security, and safety.
• Human Resources (HR) Offices: Where personnel files, contracts, and payroll records are kept.
• Time Clock Stations & Payroll Departments: Where working hours are recorded and wages are calculated.
• Cafeterias and Break Rooms: As part of the overall worker welfare assessment.
• Dormitories (if provided by the factory): These are also subject to health, safety, and living condition reviews.
• Health Clinics/First Aid Stations: To verify proper medical care and supplies.
• Environmental Areas: Such as chemical storage zones and waste disposal areas.

The entire physical plant is in scope for the audit to ensure the programs are active everywhere.

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Geographic and Jurisdictional “Where”

The requirements are not confined to the factory’s fence line. They are defined and enforced within a specific legal and geographic context.

1. The Host Country’s Legal Jurisdiction:

• The “International Standards” in WRAP’s principles first and foremost require compliance with local and national laws.
• Where are these laws from? The country, state/province, and city where the factory is physically located.
• This means a WRAP audit in Vietnam assesses compliance with Vietnamese labor law, while an audit in Honduras assesses compliance with Honduran law.

2. The Global Supply Chain (The Virtual “Where”):

• While the physical audit is at one factory, the requirement and its impact extend globally through the supply chain.
• A brand headquartered in Los Angeles can require its supplier in Bangladesh to have WRAP certification.
• Therefore, the “where” of the requirement’s influence is anywhere a brand sources from that uses WRAP as a condition of purchase.

3. The WRAP Organization’s Framework:

• The administrative “where” for the certification process is with WRAP’s headquarters and its accredited audit firms.
• The application is submitted to WRAP, the certification decision is made by their board, and the certificate is issued from their organization, even though the factory is elsewhere.

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Summary: The “Where” in Practice

Context	“Where” it Applies	Explanation
Physical Location	The Production Facility	The entire factory campus, including all buildings, production areas, and offices where workers and records are located.
Legal jurisdiction	The Country of Operation	The factory must comply with the local national and regional laws where it is physically based.
Supply Chain Influence	Global	The requirement is driven by brands and retailers around the world, affecting their suppliers in any country.
Administrative Hub	WRAP & Accredited Firms	The program is managed from WRAP’s central office, while the audits are conducted by firms located in various regions.

In conclusion, the “where” is multi-layered:

• Physically, it is the factory.
• Legally, it is the country where the factory operates.
• Economically, it is anywhere in the global supply chain that a brand requires it.

A WRAP audit is a hyper-local assessment (inside a specific factory) against global principles, driven by international market forces.

How is Required WRAP Audit and Compliance

Here is a detailed breakdown of how the required schemes and programs are implemented and verified to meet international standards through the WRAP audit and compliance process.

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The “How”: A Two-Part Process

It’s best understood as a continuous cycle with two main components:

1. How the Factory Implements the Required Systems (Internal Process)
2. How Compliance is Verified (External Audit Process)

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Part 1: How the Factory Implements the Required Systems

This is the proactive, internal work a facility must do.

1. Gap Analysis and Self-Assessment

• How it’s done: The factory management conducts a thorough internal review against the 12 WRAP Principles. They compare their current HR, health & safety, and environmental practices against the standard to identify weaknesses (e.g., “Our time records don’t accurately track overtime,” or “We lack a formal disciplinary procedure”).
• Tool Used: WRAP’s own Self-Assessment and Audit Manual.

2. Development of Formal Management Systems

• How it’s done: Based on the gap analysis, the factory writes and formalizes its policies and procedures. This is the creation of the “Required Schemes and Programs.”
  • They draft an HR Manual that prohibits child and forced labor, outlines fair recruitment, and defines disciplinary actions.
  • They establish a Health & Safety Program with written risk assessments, emergency evacuation plans, and machine safety protocols.
  • They implement a Time and Payroll System that accurately tracks and compensates all working hours.

3. Implementation and Training

• How it’s done: These new systems are not just documents. They are put into action.
  • Management Training: Supervisors and managers are trained on the new policies.
  • Worker Training: All employees are trained on their rights, safety procedures, and how to report grievances.
  • Process Integration: The new payroll system is used for every pay cycle; the new recruitment checklists are used for every hire.

4. Documentation and Record Keeping

• How it’s done: The factory meticulously maintains records that serve as evidence. This is critical for the audit.
  • Creating Records: Generating time cards, payroll slips, training attendance sheets, and safety inspection reports.
  • Organizing Records: Keeping these documents for at least 12 months, organized and readily available for review.

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Part 2: How Compliance is Verified (The WRAP Audit Process)

This is the external, independent verification of the factory’s internal systems.

1. Application and Desk Review

• How it’s done: The factory submits an application to WRAP, declaring its compliance. WRAP then assigns an independent, accredited audit firm to conduct the evaluation.

2. On-Site Audit – The Methodology

The auditor uses a multi-pronged approach to verify how the factory’s systems work in practice. This is the core of the “how.”

• a) Document Review (Verifying the “Paper” System)
  • How: The auditor selects a representative sample of employee files and traces their journey through the factory’s systems.
  • Process: They pick a worker’s file and then pull that worker’s time records, payroll records, and training records to check for consistency and legality. They verify that the numbers add up and comply with local laws.
• b) Facility Inspection (Verifying the Physical Environment)
  • How: The auditor conducts a walk-through of the entire facility.
  • Process: They check for safe machinery, clear fire exits, adequate lighting, cleanliness, availability of first aid, and proper chemical storage. This confirms that the physical reality matches the safety program.
• c) Confidential Worker Interviews (Verifying the Human Experience)
  • How: The auditor privately interviews a random selection of workers without management present.
  • Process: They ask questions about working hours, wages, treatment by supervisors, and safety training. This is the most critical step to uncover discrepancies between the documents and the workers’ actual experiences.

3. Evaluation and Corrective Action

• How it’s done: After the audit, the auditor provides a report with any non-conformities.
• Process: The factory must then use its management systems to create and execute a Corrective Action Plan (CAP) to fix the identified issues. This demonstrates that the system is not just for show but is a functional tool for continuous improvement.

4. Certification Decision

• How it’s done: The audit report and CAP are reviewed by the WRAP Certification Board.
• Process: The board determines if the evidence demonstrates full or substantial compliance with the 12 Principles and issues the corresponding certificate (Platinum, Gold, or Silver).

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Summary: The “How” in a Nutshell

The “Required Auditing Schemes and Programs” are implemented and verified through a rigorous, evidence-based process:

Step	“How” it Works for the Factory	“How” it’s Verified by the Auditor
1. Setup	Conduct a gap analysis and develop formal written programs.	Reviews the policies and manuals for completeness.
2. Operation	Integrate the programs into daily operations and train staff.	Interviews workers and managers to see if they understand and follow the procedures.
3. Documentation	Meticulously maintain 12 months of records (payroll, time, etc.).	Performs a detailed document review, tracing samples for accuracy and legality.
4. Physical Compliance	Maintain a safe, clean, and lawful physical plant.	Conducts a thorough facility inspection.
5. Improvement	Use findings (from self-assessments or audits) to drive corrective actions.	Reviews the Corrective Action Plan for effectiveness and timeliness.

In essence, the “how” is a continuous loop of:
Plan (develop the systems) -> Do (implement them) -> Check (internal self-assessment) -> Act (correct issues) -> Be Verified (external WRAP audit).

This systematic and evidence-driven methodology is what gives WRAP certification its credibility and ensures that “international standards” are met in a verifiable, consistent manner.

Case Study on WRAP Audit and Compliance

Six Sigma Quality International Pvt Ltd. & the Path to WRAP Certification

Company: Six Sigma Quality International Pvt. Ltd
Location: Vasai, Mumbai
Challenge: A major US-based client, “Urban Threads Apparel,” has mandated that all strategic suppliers must achieve a minimum of WRAP Silver certification within 12 months to remain on their vendor list.

1. The Initial Gap Analysis (The “Where We Are”)

StitchWell’s management hired a consultant to conduct a pre-assessment against the 12 WRAP Principles. The findings revealed significant gaps:

• Principle 5 & 6 (Compensation & Hours): No formal system for tracking overtime. Overtime payments were often calculated at the regular rate, and records were inconsistent.
• Principle 8 (Health & Safety): Fire exits were partially obstructed, fire drill records were fabricated for the audit, and machine guards on some sewing machines were missing.
• Principle 4 & 7 (Harassment & Discrimination): No formal, documented policy against harassment and discrimination.
• Principle 12 (Environment): No procedures for handling hazardous waste from dyeing processes.

This gap analysis became the roadmap for their project.

2. Implementing the Required Schemes and Programs (The “How”)

StitchWell established a cross-functional team led by a newly appointed Social Compliance Manager, Ms. Fatima Ahmed.

A. Management Systems Overhaul:

• Social Compliance Policy: A top-level policy was drafted, signed by the CEO, and communicated to all employees, stating StitchWell’s commitment to ethical production.
• HR Program:
  • Recruitment: Implemented a strict age-verification process to prevent child labor.
  • Compensation: Invested in a biometric time-and-attendance system to accurately track all hours worked. The payroll software was reconfigured to automatically calculate legal overtime premiums.
  • Policies: Drafted and disseminated a clear Anti-Harassment and Non-Discrimination Policy, with training for all managers.
• Health & Safety Program:
  • A dedicated EHS (Environment, Health & Safety) Committee was formed with worker representatives.
  • A schedule for monthly safety inspections and quarterly fire drills was established.
  • Machine guards were installed on all applicable machinery.
• Environmental Program:
  • Contracted with a licensed waste management company for the proper disposal of chemical dyes and solvents.

B. Documentation & Record Keeping:

• The team organized all personnel files.
• They ensured the new time and payroll systems were run in parallel for three months to build a clean, auditable record before the official audit.

3. The WRAP Audit (The Verification)

After six months of preparation, StitchWell applied for a WRAP audit. An independent, WRAP-accredited firm was assigned.

The On-Site Audit Process:

• Opening Meeting: The auditors outlined the process, emphasizing confidentiality and evidence-based verification.
• Document Review:
  • The auditors selected a sample of 30 employee files from different departments.
  • They traced these employees through the timekeeping system and payroll records. For the first time, the records matched perfectly, demonstrating compliance with Principles 5 and 6.
• Facility Inspection:
  • Auditors walked the production floor, noting the newly installed machine guards and clear fire exits.
  • They inspected the first-aid stations and reviewed the genuine, recent fire drill report with photos and attendance sheets.
• Worker Interviews:
  • In confidential sessions, workers confirmed they had received their correct overtime pay in recent months.
  • Several workers mentioned the new anonymous grievance box and stated that they had attended the new health and safety training.

4. Audit Findings and Corrective Action Plan (CAP)

The audit report highlighted two minor non-conformities:

1. Documentation: The new Anti-Harassment Policy had not been posted in all common areas in the required languages (it was only in Bengali, not also in English).
2. Procedure: The hazardous waste disposal manifests from the new contractor were not being systematically filed for review.

These were not major systemic failures but gaps in the implementation of their new programs.

StitchWell’s Response:
Ms. Ahmed immediately implemented a Corrective Action Plan (CAP):

• The policy was translated and posted in all break rooms within one week.
• A log was created for the EHS manager to sign off on all waste manifests upon receipt.

The CAP and supporting evidence were submitted to the audit firm for review.

5. Outcome and Certification

The WRAP Certification Board reviewed the full audit report and the effective closure of the CAP. They concluded that StitchWell Garments had demonstrated substantial compliance with all 12 WRAP Principles.

They were awarded a WRAP Silver Certificate, valid for one year.

• For StitchWell: They retained their contract with UrbanThreads Apparel and began marketing their WRAP certification to other potential clients.
• For UrbanThreads Apparel: They could confidently list StitchWell as a compliant supplier in their own CSR report, mitigating their supply chain risk.

6. The Continuous Cycle

Six Sigma Quality International did not stop. Their goal is now to achieve Gold certification in the next cycle. They continue to operate their required programs daily, using internal audits to ensure they remain in compliance, embodying the true spirit of continuous improvement required by international standards like WRAP.

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Key Takeaways from the Case Study

1. It’s a Project, Not an Event: Achieving compliance requires a structured, management-led project with dedicated resources.
2. Gap Analysis is Critical: You cannot fix what you don’t know is broken. An honest self-assessment is the essential first step.
3. Systems Over Quick Fixes: The solution was not to falsify records for the audit but to implement a genuine, automated timekeeping and payroll system that would ensure long-term compliance.
4. Evidence is Everything: The audit is a forensic exercise in matching documents (payroll) with physical evidence (the factory floor) and human testimony (worker interviews).
5. Certification is a Journey: The Silver level acknowledges the factory is on the right path. The requirement to maintain and improve these programs is continuous, driving the facility toward higher levels of performance (Gold and Platinum).

White paper on WRAP Audit and Compliance

Abstract

In an era of heightened consumer consciousness and stringent regulatory environments, the demand for transparent, ethical, and socially responsible manufacturing has never been greater. This white paper examines the critical role of independent auditing schemes and programs in verifying compliance with international labor, safety, and environmental standards. It provides a detailed analysis of the Worldwide Responsible Accredited Production (WRAP) certification system as a leading model. The document outlines the framework of “required schemes and programs,” the WRAP audit process, the business case for compliance, and a strategic roadmap for implementation. The conclusion affirms that robust, system-based auditing is not merely a cost of doing business but a fundamental driver of risk mitigation, operational excellence, and long-term brand value.

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1. Introduction: The Imperative for Ethical Verification

Global supply chains are complex and often opaque. For brands, retailers, and consumers, ensuring that products are made responsibly is a significant challenge. Incidents of labor exploitation, unsafe working conditions, and environmental damage can cause irreparable reputational harm, legal liability, and supply chain disruption.

Auditing schemes and programs to international standards provide a vital solution. They offer a structured, verifiable, and consistent methodology to assess a production facility’s adherence to globally accepted principles of social responsibility. Among these, the WRAP certification has emerged as a gold standard, particularly in the apparel, footwear, and sewn products sectors.

2. Understanding the Framework: Required Schemes and Programs

Compliance is not a passive state but an active, managed process. The foundation of any successful audit lies in the pre-existing “Required Schemes and Programs”—the formal management systems and documented procedures that ensure daily operations meet international benchmarks.

These required elements can be categorized as follows:

• Management Systems: A top-level Social Compliance Management System with defined policies, objectives, and managerial accountability.
• Human Resources (HR) Programs: Documented procedures for recruitment (preventing child/forced labor), compensation (accurate time and payroll tracking), and disciplinary actions (prohibiting harassment and discrimination).
• Health & Safety (EHS) Programs: Formal protocols for risk assessment, emergency preparedness, incident reporting, and worker training.
• Environmental Programs: Procedures for managing waste, chemicals, and emissions in compliance with local laws.
• Documentation & Records: The evidence of implementation, including personnel files, 12 months of time/payroll records, training logs, and inspection reports.

Without these embedded systems, an audit becomes a superficial snapshot, unable to verify sustained compliance.

3. The WRAP Standard: A Principles-Based Approach

WRAP’s effectiveness stems from its clear, comprehensive, and principles-based framework. The 12 WRAP Principles are rooted in international standards, primarily International Labour Organization (ILO) conventions and local laws.

The 12 Principles are grouped into three categories:

1. Compliance with Laws and Workplace Regulations (Principles 1-4)
2. Respect for Workers and Their Rights (Principles 5-9)
3. Conformance with Customs and Environmental Requirements (Principles 10-12)

WRAP’s tiered certification model (Platinum, Gold, Silver) acknowledges that compliance is a journey, incentivizing continuous improvement rather than punishing initial imperfection.

4. The WRAP Audit Process: A Mechanism of Verification

The WRAP audit is the independent verification mechanism that tests the facility’s required schemes and programs. It is a rigorous, evidence-based process:

1. Self-Assessment & Application: The facility conducts an internal audit and applies to WRAP.
2. On-Site Audit by an Accredited Firm: An independent third-party conducts a comprehensive review.
3. Multi-Faceted Verification Methods:
   • Document Review: A forensic analysis of records to verify payment of wages and working hours.
   • Facility Inspection: A physical walk-through to assess health, safety, and working conditions.
   • Confidential Worker Interviews: Private sessions to corroborate management records and uncover potential issues.
4. Corrective Action Plan (CAP): Identified non-conformities must be addressed through a formal CAP.
5. Certification Decision: The WRAP Certification Board reviews the entire package before issuing a certificate.

This multi-pronged approach ensures that a facility’s paperwork aligns with both its physical reality and its workers’ experiences.

5. The Business Case: Why WRAP Compliance Matters

Implementing the required schemes for WRAP certification is a strategic investment with a clear return.

• For Production Facilities (Suppliers):
  • Market Access: A WRAP certificate is a prerequisite for doing business with many major global brands.
  • Operational Efficiency: Standardized systems for HR, payroll, and safety reduce errors and improve productivity.
  • Improved Morale and Retention: Ethical treatment of workers leads to a more stable and motivated workforce.
  • Competitive Differentiation: Certification is a powerful marketing tool to attract new clients.
• For Brands and Retailers (Buyers):
  • Supply Chain De-risking: Proactively identifies and mitigates reputational, legal, and operational risks.
  • Brand Protection and Enhancement: Demonstrates a commitment to Corporate Social Responsibility (CSR) to consumers and investors.
  • Audit Efficiency: Reduces the need for redundant audits, saving time and resources.

6. Implementation Roadmap: A Strategic Journey to Compliance

Achieving and maintaining WRAP compliance requires a systematic approach:

1. Commitment & Gap Analysis: Secure top-management buy-in and conduct an honest assessment against the 12 Principles.
2. Develop & Document Systems: Create the required policies, manuals, and procedures.
3. Implement & Train: Roll out systems across the organization and train all levels of staff.
4. Operate & Record: Run the new systems for a sufficient period (ideally 3-6 months) to generate a clean, auditable record trail.
5. Internal Audit & Correct: Conduct a mock audit to identify and fix final gaps.
6. Undergo External WRAP Audit: Engage with the official process.
7. Continuous Improvement: Use the audit findings and CAP to drive ongoing enhancements, aiming for a higher certification level.

7. Conclusion

The landscape of global manufacturing is shifting irrevocably towards greater accountability. Auditing schemes and programs to international standards, exemplified by the WRAP system, provide the necessary framework to navigate this shift successfully. For suppliers, it is a pathway to operational excellence and market competitiveness. For brands, it is an essential tool for building resilient, ethical, and trustworthy supply chains. Moving beyond a checkbox mentality to embrace the spirit of continuous improvement embedded in programs like WRAP is not just the right thing to do—it is the foundation of sustainable business success in the 21st century.

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8. Appendices

• Appendix A: The 12 WRAP Principles (Detailed List)
• Appendix B: Glossary of Terms (e.g., CAP, Non-conformity, EHS)
• Appendix C: Further Resources (Links to WRAP, ILO, etc.)

Industrial Application of WRAP Audit and Compliance

The theoretical framework of social compliance is only as valuable as its practical, on-the-ground application. In an industrial setting, auditing schemes like WRAP are not abstract concepts but operational blueprints that transform ethical principles into daily routines, management systems, and verifiable outcomes.

This section details how the “Required Schemes and Programs” are applied within a manufacturing facility to achieve and maintain WRAP compliance.

1. Application in Core Industrial Operations

The WRAP principles are integrated directly into the primary functions of a factory.

A. Human Resources (HR) and Labor Management:

• Application: The HR department transitions from a purely administrative function to the guardian of ethical labor practices.
• Practical Examples:
  • Recruitment: Implementing a digital onboarding system that mandates age verification scans (to prevent child labor) and ensures contracts are voluntary and understood (to prevent forced labor).
  • Payroll & Timekeeping: Integrating biometric time clocks with payroll software. The system automatically flags when workers approach legal overtime limits and calculates premiums correctly, ensuring compliance with Principles 5 & 6.
  • Grievance Mechanisms: Installing anonymous suggestion boxes and establishing a clear, confidential procedure for workers to report harassment or discrimination (Principles 4 & 7), managed by a designated HR officer.

B. Production Floor and Health & Safety (EHS):

• Application: The production floor is managed not just for output, but for worker safety and well-being.
• Practical Examples:
  • Machine Safety: Regular maintenance logs for all sewing machine guards. A “Lockout-Tagout” (LOTO) procedure is implemented for machine repair, preventing accidental startup (Principle 8).
  • Ergonomics: Workstations are assessed and modified to reduce repetitive strain injuries.
  • Chemical Management: In a fabric dyeing unit, Safety Data Sheets (SDS) for all chemicals are maintained, and workers are provided with and trained to use proper personal protective equipment (PPE) like gloves and masks.
  • Emergency Preparedness: Clearly marked, unobstructed evacuation routes with illuminated signs. Quarterly, documented fire drills that involve all shifts (Principle 8).

C. Supply Chain and Logistics:

• Application: Ethical compliance extends to how materials and finished goods are handled and shipped.
• Practical Examples:
  • Security Protocols: Controlled access to shipping areas, surveillance of loading docks, and pre-employment background checks for security staff to prevent the introduction of contraband (Principle 11).
  • Documentation: Maintaining meticulous shipping records and purchase orders to demonstrate compliance with customs laws and prevent illegal transshipment (Principle 10).

D. Environmental Management:

• Application: Environmental responsibility is systematized.
• Practical Examples:
  • Waste Management: Partnering with licensed waste haulers for hazardous materials (e.g., chemical dyes, solvents) and maintaining signed manifests for every disposal event (Principle 12).
  • Resource Reduction: Implementing water recycling in dyeing vats or investing in energy-efficient lighting to reduce environmental impact and operational costs.

2. The Role of Industrial Management

The application is driven by a cross-functional management structure:

• Top Management: Provides the budget, authority, and public commitment. They are ultimately responsible for the compliance program’s success.
• Social Compliance / HR Manager: The project lead. This person translates the WRAP principles into actionable policies, trains other departments, maintains the overall system, and serves as the point of contact for the audit.
• Production Managers & Supervisors: Enforce safety rules on the floor, ensure accurate timekeeping, and foster a culture of respect.
• EHS Officer: Conducts risk assessments, safety training, and emergency drills.

3. The Audit as an Industrial Health Check

In an industrial context, the WRAP audit is not a test to be passed, but a diagnostic health check for the facility’s management systems.

• The Auditor as an Industrial Engineer: The auditor traces the “product” of ethical compliance through the factory’s “production line.” They take a sample worker and follow their data trail from hiring (HR files) to hours worked (time records) to payment (payroll), verifying the integrity of the system at each step.
• Focus on Systemic Flaws, Not Individual Errors: The goal is to find broken processes, not to punish a single missed fire drill. For example, if payroll consistently miscalculates overtime, the finding is against the payroll system, not the individual clerk.

4. Tangible Industrial Benefits of Application

The investment in these systems yields concrete returns:

• Increased Operational Efficiency: Automated, accurate payroll and timekeeping reduce administrative errors and disputes.
• Reduced Downtime: A safer workplace has fewer accidents, leading to less production disruption.
• Lower Employee Turnover: Ethical treatment improves morale and retention, reducing the high costs of recruiting and training new workers.
• Enhanced Brand Reputation: The WRAP certificate becomes a powerful marketing tool, attracting business from top-tier brands.
• Risk Mitigation: Prevents catastrophic shutdowns due to labor unrest, safety incidents, or the loss of a major client.

Conclusion

The industrial application of the WRAP audit and compliance framework is the critical process of embedding ethics into the very DNA of a manufacturing operation. It moves social responsibility from a public relations statement to a series of managed, measured, and audited processes integrated across HR, production, safety, and environmental departments. For forward-thinking industrial facilities, this application is not a burden but a strategic lever for achieving operational excellence, securing a competitive advantage, and building a sustainable, resilient business model for the global market.