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Code of Business Practices – ICTI Audit

The International Council of Toy Industries (ICTI), an association of associations, is committed on behalf of its member companies to the operation of associations, is committed on behalf of its member companies to the operation of toy factories in a lawful, safe, and healthful manner. It upholds the principles that no underage, forced, or prison labor* should be employed; that no one is denied a job because of gender, ethnic origin, religion, affiliation or association, and that factories comply with laws protecting the environment. Supply agreements with firms manufacturing on behalf of ICTI members must also provide for adherence to these principles. The role of ICTI is to inform, educate, and survey its members so that individual member companies can adhere to its Code of Business Practices. As an association, it also acts to encourage local and national governments to enforce wage and hour laws and factory health and safety laws.

Specific operating conditions that member companies are expected to meet and obtain contractor agreement in advance are as follows:

Labor

that working hours per week, wages and overtime pay practices comply with the standards set by law or, in the absence of a law, address humane, safe and productive working conditions;
that no one under the legal minimum age is employed in any stage of toy manufacturing; that a minimum age of 14 applies in all circumstances, but notwithstanding the foregoing, that C138 Minimum Age Convention (1973) and C182 Worst Forms of Child Labor Convention (1999) of the International Labor Organization apply;
that no forced or prison labor is employed*, that workers are free to leave once their shift ends, and that guards are posted only for normal security reasons;
that all workers are entitled to sick and maternity benefits as provided by law;
that all workers are entitled to freely exercise their rights of employee representation as provided by local law.

The Workplace

that toy factories provide a safe working environment for their employees and comply with or exceed all applicable local laws concerning sanitation and risk protection;
that the factory is properly lighted and ventilated and that aisles and exits are accessible at all times;
that there is adequate medical assistance available in emergencies, and that designated employees are trained in first aid procedures;
that there are adequate and well-identified emergency exits, and that all employees are trained in emergency evacuation;
that protective safety equipment is available and employees are trained in its use;
that safeguards on machinery meet or exceed local laws;
that there are adequate toilet facilities which meet local hygiene requirements, and that they are properly maintained;
that there are facilities or appropriate provisions for meals and other breaks;
if a factory provides housing for its employees, it will ensure that dormitory rooms and sanitary facilities meet basic needs, are adequately ventilated and meet fire safety and other local laws;
that no mental or physical disciplinary practices are employed.

Compliance

The purpose of this Code is to establish a standard of performance, to educate, and to encourage commitment to responsible manufacturing, not to punish.
To determine adherence, ICTI member companies will evaluate their own facilities as well as those of their contractors. They will examine all books and records and conduct on-site inspections of the facilities, and request that their contractors follow the same practices with subcontractors.
An annual statement of compliance with this Code must be signed by an officer of each manufacturing company or contractor.
Contracts for the manufacture of toys should provide that a material failure to comply with the Code or to implement a corrective action plan on a timely basis is a breach of contract for which the contract may be canceled.
Because of the great diversity in the kinds of toys manufactured and the manufacturing methods used, as well as the wide range in factory sizes and numbers of employees, three annexes are attached to this Code to provide guidelines for determining compliance. A rule of reason must be used to determine applicability of the annex provisions.
This Code should be posted or available for all employees in the local language.

* Many countries recognize that prison labor is essential to the rehabilitation process. This provision prohibits the exportation of prison-made goods to countries that prohibit or restrict the importation of such goods.

Methodology for Evaluating Compliance

While evaluating compliance, the following procedures are deemed necessary:

check local laws
conduct on-site visit/inspection
interview workers

Child Labor

Check local laws

Check written factory policy and procedures

Check worker's identification by random sampling

Check personnel record of "questionable" young workers

Interview "questionable" workers

Check any other evidence

Prison/Forced Labor

Prison Labor

Check local laws

Check written factory policy and procedures

Perform unannounced visit

Check subcontractors list

Check any other evidence

Forced Labor

Check local laws

Interview workers

Check written factory policy and procedures

Check voluntary overtime record

Check any other evidence

Working Hours

Check written factory policy and procedures

Check local laws

Conduct random punch card checks and compare with payroll records

Interview workers

Check any other evidence

Wages and Compensation

Check written factory policy and procedures (e.g., insurance, medical, accommodation, etc.)

Check local laws

Check payroll records

Interview workers

Check any other evidence

Discrimination

Check written factory policy and procedures

Check local laws

Check any other evidence

Working Conditions

Conduct on-site inspection(s)

Interview workers

Check written factory policy and procedures

Check local laws

Check injury/illness records

Check any other evidence

Industrial Safety

Check local laws

Check written factory policy and procedures

Conduct on-site inspection(s)

Inspect factory accident log

Refer to "ICTI Fire Prevention & Emergency Preparedness Manual"

Check any other evidence