What is WRAP Standards and WRAP Certification Process

Wrap standards and certification process

I had the opportunity to visit the WRAP stall and have a constructive discussion with their representatives (in 2019) about the certification process and its importance to the industry. Ms. Darlene Ugwa, Manager of Education & Business Development, and Mr. Clay Hickson, Senior Director of Strategy, explained the history of WRAP and its outlook for the industry.

WRAP, an acronym for Worldwide Responsible Accredited Production, is the world’s largest independent factory-based social compliance certification program for the sewn products sector. Its headquarters is based at 2200 Wilson Boulevard, Suite 601, Arlington, Virginia, which is five miles from Washington DC, the capital of the United States.

WRAP is a must-have certification for many apparel manufacturers if they want to export to buyers and retailers in the USA. Retailers such as GAP, Nike and Walmart routinely request manufacturers to have a valid WRAP certification even though they themselves have their own certification and compliance process. In other words, WRAP is a necessary stepping stone for those interested in exporting to USA based buyers. It is important to note here that according to the Clay Hickson, WRAP is aggressively pushing to expand in Europe. This means WRAP certification will soon be a must for companies predominately exporting to countries in Europe.

WRAP is founded on 12 principles based on generally accepted international workplace standards, local laws, and workplace regulations, and includes the spirit or language of relevant conventions of the International Labor Organization (ILO). The principles encompass human resources management, health and safety, environmental practices, and legal compliance, including import/export and customs compliance and security standards.

Related post: 20 Certifications and Standards for Textile Industry Businesses

The WRAP Certification Program’s objective is to independently monitor and certify compliance within these standards to ensure that sewn products are being produced under lawful, humane and ethical conditions. Participating facilities voluntarily commit to ensuring that their manufacturing practices will meet these standards and further commit to passing along, on their part, the expectation that their contractors and suppliers, likewise, comply with the following twelve standards:

1. Compliance with Laws and Workplace Regulations

Facilities will comply with laws and regulations in all locations where they conduct business.
All facilities will comply with the legal requirements and standards of their industry under the local and national laws of the jurisdictions in which the facilities are doing business, along with any applicable international laws. This will cover all labor and employment laws of those jurisdictions, as well as laws governing the conduct of business in general, including rules and standards of ethics dealing with corruption and transparency, and any relevant environmental laws.

2. Prohibition of Forced Labor

Facilities will not use involuntary, forced or trafficked labor.

Facilities will maintain employment strictly on a voluntary basis. Facilities will not use any forced, prison, indentured, bonded or trafficked labor. This will include ensuring that any workers they hire will be under labor contracts that fully comply with all relevant legal requirements and do not impose any form of coercion (including imposing substantial fines or loss of residency papers by workers leaving employment or restricting a worker’s ability to voluntarily end his/her employment). In addition, when hiring workers through an employment broker or agency, facilities will ensure that the workers’ passports are not withheld, all written contracts are in the native language of the workers, and recruitment fees are not borne by the workers themselves.

3. Prohibition of Child Labor

Facilities will not hire any employee under the age of 14 or under the minimum age established by law for employment, whichever is greater, or any employee whose employment would interfere with compulsory schooling.

Facilities will ensure they do not engage in any form of child labor, including, but not limited to, the internationally recognized worst forms of child labor. Facilities may not employ any person at an age younger than the law of the jurisdiction allows and in any case not below the age of 14, even if permitted by local law. In addition, facilities will adhere to local legal requirements regarding mandatory schooling. Further, if, where permitted by local law, a facility employs young workers (defined as workers whose age is between the minimum age of employment and 18 years), the facility will also comply with any applicable legal restrictions on the nature and volume of work performed by such young workers, as well as any other requirements imposed by law, including ensuring that such young workers do not perform any hazardous work (e.g., chemical handling or operating heavy machinery).

4. Prohibition of Harassment or Abuse

Facilities will provide a work environment free of supervisory or co-worker harassment or abuse, and free of corporal punishment in any form.

Facilities will ensure a workplace that is respectful of a worker’s rights and dignity. This includes ensuring that no corporal punishment or physical coercion be used. Facilities will not engage in or tolerate sexual harassment, indecent or threatening gestures, abusive tone or language or any other kind of undesired physical or verbal contact, such as bullying. In particular, facilities will ensure proper training at all levels - including management, supervisors and workers - to secure a workplace free of harassment or abuse.

5. Compensation and Benefits

Facilities will pay at least the minimum total compensation required by local law, including all mandated wages, allowances & benefits.

Facilities will ensure proper compensation for their employees for all the work done, by providing in a timely manner all the wages and benefits that are in compliance with the local and national laws of the jurisdiction in which they are located. This will include any premiums for overtime work or work done during holidays, as well as any other allowances or benefits, including any mandatory social insurance, required by local law.

6. Hours of Work

Hours worked each day, and days worked each week, should not exceed the limitations of the country’s law. Facilities will provide at least one day off in every seven-day period, except as required to meet urgent business needs.
Facilities are required by local law to adhere to any limits set on regular working hours as well as any limits set on overtime work. Long term participation in the WRAP Certification Program is contingent upon meeting the limitations set by local law. WRAP recognizes that this can be a particularly challenging requirement, especially when taking into account local enforcement norms and customs. In light of this reality, WRAP will permit full compliance with local laws on working hours to be achieved incrementally, provided that a given facility meets the following conditions: is fully transparent about its working hours; ensures that those hours are all being worked voluntarily, in conditions that protect worker safety and health; compensates all employees in keeping with WRAP Principle 5; and shows improvement toward meeting the working hours requirements from one audit to the next.

7. Prohibition of Discrimination

Facilities will employ, pay, promote, and terminate workers on the basis of their ability to do the job, rather than on the basis of personal characteristics or beliefs.

Facilities will ensure that all terms and conditions of employment are based on an individual’s ability to do the job, and not on the basis of any personal characteristics or beliefs. Facilities will ensure that any employment decision - involving hiring, firing, assigning work, paying or promoting - is made without discriminating against the employees on the basis of race, color, national origin, gender, sexual orientation, religion, disability, or other similar factors (pregnancy, political opinion or affiliation, social status, etc.).

8. Health and Safety

Facilities will provide a safe and healthy work environment. Where residential housing is provided for workers, facilities will provide safe and healthy housing.

Facilities will provide a safe, clean, healthy and productive workplace for their employees. Facilities shall prioritize worker health and safety above all else, and proactively address any safety issues that could arise. This will include a wide variety of requirements, such as, ensuring, among other things, the availability of clean drinking water (at no charge to workers), adequate medical resources, fire exits and safety equipment, well-lighted and comfortable workstations, clean restrooms. Further, facilities shall adequately train all their workers on how to perform their jobs safely

9. Freedom of Association and Collective Bargaining

Facilities will recognize and respect the right of employees to exercise their lawful rights of free association and collective bargaining.

Facilities will respect the freedom of each employee to choose for him or herself whether or not to join a workers’ association. Facilities cannot discriminate against workers based on whether or not they choose to associate. Both the facility and the workers shall ensure they conduct themselves in accordance with all relevant laws in this regard. Facilities will ensure an effective mechanism is in place to address any workplace grievances.

10. Environment

Facilities will comply with environmental rules, regulations and standards applicable to their operations, and will observe environmentally conscious practices in all locations where they operate.

Facilities will ensure compliance with all applicable legally mandated environmental standards, and should demonstrate a commitment to protecting the environment by actively monitoring their environmental practices. In particular, facilities will ensure proper waste management, including monitoring the disposal of any waste material - whether solid, liquid or gaseous - to ensure such disposal is done safely and in a manner consistent with all relevant laws.

11. Customs Compliance

Facilities will comply with applicable customs laws, and in particular, will establish and maintain programs to comply with customs laws regarding illegal transshipment of finished products.

Facilities will ensure that all merchandise is accurately marked or labelled in compliance with all applicable laws. In addition, facilities will keep records for all materials and orders, as well as maintain detailed production records.

12. Security

Facilities will maintain facility security procedures to guard against the introduction of non-manifested cargo into outbound shipments (i.e. drugs, explosives biohazards and/or other contraband).

Facilities will ensure adequate controls are in place to safeguard against introduction of any non-manifested cargo. In this regard, WRAP recognizes the United States Customs and Border Protection (CBP)’s C-TPAT Guidelines for Foreign Manufacturers as a best practice program, and has adopted those guidelines under this Principle.

WRAP Certification process

WRAP use third-party accredited monitors to inspect and certify the manufacturing plants. Randomly, WRAP will send their own inspectors to check the work carried out by the third-party accreditors to ensure the quality of the inspection. WRAP’s auditing partners need to meet rigorous accreditation requirements and undergo a 5-day training course conducted by WRAP and they need to attend refresher training courses once every two years. 

WRAP has detailed policies for recognition of monitoring partners. the threshold requirements of the accredited partners include Independence where the accredited company has no financial or legal interest of the company their inspecting and refrain from receiving financial or any other compensation apart from the relevant fees. Depending on the availability, each country has several accredited monitors. For example, Sri Lanka has 5 accredited monitors while Bangladesh has 6. India has 11 accredited monitors. 

The Cost

WRAP certification has several cost factors involved.

Annual membership registration fee which needs directly paid to WRAP is US$1195.

Certification cost for Sri Lanka is average US$500 (for a company with 150 employees) + travelling fees.

India is US$1000 + travelling cost. That cost increases to US$1200 if the factory has dormitory facilities as the accredited agency need to spend extra days to conduct inspections.

Bangladesh also charges similar to India. It is important to note that the inspection fee is calculated based on the number of employees. The more the employees, the higher the fees.
The manufacturer has to pay for an inspection team re-visit in the event of a failed initial inspection. It is therefore important to ensure all areas are properly checked and all requirements are met prior to the visit of inspectors. The inspections are done without a prior notice hence its important to ensure all areas are self-assessed and in compliant with all guidelines.

PS: Please check http://wrapcompliance.org/ for current rates and costs components. 

WRAP has 3 levels of certifications:

  1.  Platinum
  2.  Gold
  3.  Silver
Companies maintaining high standards and not failing an audit for 3 years receive platinum certification. Platinum certification allows the manufacturer to get an additional 2 years of WRAP membership without having to pay the membership fee of US$1150 with a total savings of US$2300. Gold members are certified for 1 year, and companies with noted compliance problems become silver members and are required to be inspected every 6 months.

It is important to note that WRAP gives a 10% discount to manufacturers joining in a group of 10 companies. For example, if the Sri Lankan Apparel Exporter’s Association applies for certification for all their members, each company in the association will receive a 10% discount.

Source http://wrapcompliance.org

Charm Rammandala

Dr. Charm Rammandala currently works as the Sustainable Program Manager at Apple Inc. USA. He has over 20 years of international management experience and previously contributed his expertise at Tesla, George Sourcing, and Vomax LLC.

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