While we believe monitoring is still an important element of any effort to raise compliance levels, we strongly advocate a shift from only monitoring to monitoring that supports capacity building and continuous improvement. Nonetheless, Level Works labor compliance assessments are executed against a company and/or industry code of conduct (COC) using only local, well trained, and experienced field staff. Initial compliance assessments generally last from 1-4 person days, and follow-up assessments from 1-2 person days. Our staff have conducted thousands assessments around the world in a thorough and culturally sensitive manner. As a result, we posses a clear understanding of regional and country specific trends and challenges related to factory compliance and assessment methodology. All assessments include corrective action plans with pragmatic solutions designed to assist our clients and their suppliers with remediation, capacity building and continuous improvement.

The purpose of the labor compliance assessment is to determine and report on a particular factory's level of compliance with local laws and/or client standards. The purpose of this is to promote increased awareness of labor conditions within the supply chain and to facilitate corrective action. The assessment process itself requires that information be gathered from management interviews, employee interviews, visual observation, and document/records review. Initial visits generally last from 1-4 person days, and follow-up visits from 1-2 person days. The success of each assessment depends largely on the willingness of the factory management to provide access to factory grounds, relevant records, and employees for interview.

• Factory contact
• Applicable country specific laws and standards
• Appropriate client documentation and instructions
• Supplier and factory profile information
• Self assessment questionnaires
• Review of previous assessment reports and history
• Review of all outstanding corrective action plans
• Names of employees interviewed during previous assessment
• Media allegations

• Show respect and courtesy to management!
• Introduce each member of the Level Work's team
• Establish appropriate communication channels
• Review the scope and goals of the assessment
• Provide management with a specific list of records that will be needed for review
• Request a factory floor plan
• Discuss the assessment team's role as an objective verifier only
• Present and discuss the client Code of Conduct (COC) and/or standards
• Interview factory management about operational processes.

In determining compliance, information gathered through visual observation is critical. For this reason Level Work's staff is trained to do a detailed and in-depth observation/review of the workplace health, safety and environmental conditions, with a focus on how those conditions impact the employees. Our staff will also observe employees for signs that might relate to other areas of compliance. For example; how managers, supervisor, and employees interact amongst themselves and with one another. In general, Level Work's staff is instructed to draw upon his/her common sense and professional experience. If something doesn't seem right a more detailed analysis will be undertaken, which might include additional document review and/or employee interviews.

Confidential interviews with employees are fundamental to the success of the assessment because they provide the most pure source of information about how working conditions impact employee well being. However, employee interviews require great care and sensitivity to local conditions, and must always be conducted in a manner that ensures that employees will not face retaliation as a result of their participation. Specifically, Level Work's staff is expected to crosscheck information gathered from other information sources, detect potential areas of concern, and to assess the awareness level of the employees during each interview. Our role during the assessment is not to educate, debate, or argue with employees for any reason.

Documents and records review is done for a number of reason which include; gathering information regarding wages and benefits, hours of work, company policies, discrimination, health & safety, child labor, etc. Prior to reviewing records Level Works staff must first familiarize themselves with the procedures and systems of the factory. As well as checking the content of the documents and records, it's also important to assess how they are controlled to ensure ongoing compliance. Are the right documents available in the right places and to the right people? Are they up to date?

During the assessment, Level Works strives to be objective and make good, unbiased judgments concerning compliance. Although data from objective and subjective information sources is collected during each visit, we will remain objective when making decisions. One of the most important parts of this, is the cross checking of information gathered during each part of the assessment. Without systematically comparing and crosschecking information gained from employee interviews, management, document & record review, and visual observation; important findings will be missed. Thus, Level Work's staff is specifically trained to authenticate provided documentation throughout the assessment process. The increased use of record falsification by factories underscores the importance of thiselement of the assessment.

Once the assessment is complete, a closing meeting will be held with factory management. During this meeting, management will be provided a final opportunity to clarity factory policies and practices as they relate to each non-conformity. This is of particularly importance when inconsistent and/or unclear data has been collected. Generally the closing meeting includes;

• Acknowledgement of factory management cooperation
• Restatement of the purpose of the assessment
• Presentation and review of a draft list of each non-conformity
• Discussion of recommended corrective action steps