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Indicator 1.4.4
Requirement
Indicator applicability: every UoC using compound feed The UoC shall disclose to all buyers of their ASC certified product when a product’s feed contains >0.9%77European Council. (2003). Regulation (EC) No 1830/2003 concerning the traceability and labelling of genetically modified organisms and the traceability of food and feed products produced from genetically modified organisms and amending Directive 2001/18/EC. European Parliament, Council of the European Union. Genetically Modified Organisms (GMO) or macro ingredients produced from GMO.
How Do I Interpret This Requirement?
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The required disclosure is to the UoC’s buyers of ASC certified products.
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A public disclosure is possible but not required.
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The UoC shall ensure buyers are informed when a product’s feed contains or is produced from GMO.
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Disclosure may be provided to buyers individually or collectively.
Evidence of Implementation
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Records:
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disclosure to buyers.
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Auditors Should Confirm
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Evidence of disclosure to buyers.
Indicator 1.4.3
Requirement
Indicator applicability: every UoC using compound feed The UoC shall demonstrate that feed products, subject to conformance with Indicator 2.12.1, are accompanied by the following information: a. the originating feed mill holds valid certification against the ASC Feed Standard with the appropriate scope of certification in relation to the ASC Production Model (i.e. Mass Balance Production Model or Segregation Production Model product); and b. feed is traceable as ASC-conforming throughout all steps between the feed mill and site; and c. documentation accompanying the feed identifies the feed as ASC-conforming; and d. documentation accompanying the feed identifies the production model applied (i.e. Mass Balance Production Model or Segregation Production Model); and e. for ASC-conforming Segregation Production Model feed, the product is identifiable by a distinct feed name in formal documentation accompanying the product and is listed on the schedule to the feed mill certificate.
How Do I Interpret This Requirement?
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Indicator 2.12.1 requires the UoC to only use ASC-conforming compound feed.
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Use of non-conforming feed will be treated as a non-conformity against Indicator 2.12.1.
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For product which is sold under the segregation model, identifying the feed production model and distinct feed name is required by the ASC Feed Standard, Indicator 3.3.2.
Evidence of Implementation
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Process to confirm the originating feed mill holds valid certification against the ASC Feed Standard.
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Records:
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traceability system and its verification, for example:
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use of a digital traceability system
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outcome of any input-output exercises and traceability tests.
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accompanying documents incorporating information required by 1.4.3(c), (d) and (e).
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Auditors Should Confirm
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Process to confirm the originating feed mill holds valid certification against the ASC Feed Standard.
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Effective traceability and segregation systems are in place.
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Outcome of any input-output exercises and traceability tests.
Indicator 1.3.2
Requirement
The UoC shall ensure that information provided as evidence of conformance to the ASC Requirements is not falsified or misrepresented.
How Do I Interpret This Requirement?
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Records are documented information that provides permanent evidence about past events. They should:
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Be completed and maintained in a way that ensures information is accurate and preserved;
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Be genuine;
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they should be completed at the time of the checks or shortly after.
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Capture and illustrate information when processes do not perform as expected.
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for example, if the cooling system ceases to work, it is important that temperatures above the acceptable range according to internal requirements are recorded so that management can learn from these events.
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recording temperatures only within the acceptable range will lead to management not understanding that a backup temperature regulator might be needed.
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Be legible;
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Be complete;
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which may include a form of authorisation through the initials of the supervisor verifying records are complete;
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Be stored appropriately:
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paper records should be stored in a way that prevents damage.
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where records are stored electronically, this storage should be backed up.
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If incidences of falsification of records or misrepresentation of information are identified, corrective action and actions to prevent recurrence should be taken.
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Evidence of Implementation
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Records:
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that demonstrate genuineness.
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corrective action and actions to prevent recurrence when incidences of falsification of records or misrepresentation of information are identified.
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Auditors Should Confirm
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records and their genuineness
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effectiveness of corrective action and actions to prevent
Indicator 1.3.1
Requirement
The UoC shall discourage all forms of corruption and shall encourage ethical behaviour and integrity in their business operations.
How Do I Interpret This Requirement?
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Corruption can:
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Happen anywhere;
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Involve anyone;
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Take many forms. For example:
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extortion
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embezzlement
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bribery
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Examples of corruption are:
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A manager buys supplies from a friend and in return, the friend gives 20% of the profits to the manager. This may go as far as the manager excluding other appropriate suppliers from the system of approved suppliers.
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A piece of infrastructure has an unsafe mechanism and the owner pays the manager cash to not disclose this at the next audit.
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Examples of extortion are:
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Employee A threatens to provide information to the manager which could get Employee B into trouble or fired, unless Employee A is paid a requested amount of money.
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A site owner threatens to hurt the owner of the neighbouring plot of land unless the land-owner agrees to give up some of his land so that the site can build an additional building.
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Examples of embezzlement are:
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A site manager getting cash from the first point of sale in exchange for under-declaring harvest volumes (i.e. the purchaser receiving more product that they are paying for).
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A sourcing manager purchases cheaper non-eligible feed but registers them as eligible and provides documentation falsely declaring it as more costly eligible feed, as financial sourcing performance increases the sourcing manager’s bonus.
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Examples of bribery are:
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A supplier buys a new car for a site manager, in exchange for the site manager giving the sourcing contract to that supplier.
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A site pays cash to customs officials to speed up the passage of their feed through the import and export system.
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A sustainability manager offers auditors excessive accommodation and lunches to reduce the audit effort or to turn a blind eye to non-conformities.
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Evidence of Implementation
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Policies preventing corruption, including extortion, embezzlement and bribery.
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Terms of dismissal should employees engage in these practices.
Auditors Should Confirm
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Management and employees are aware of:
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what these practices involve and how to recognise them.
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the policies in place for preventing corruption, including extortion, embezzlement and bribery.
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Useful Resources
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Transparency International: <https://www.transparency.org/en>
Indicator 1.2.4
Requirement
The UoC shall annually review the management system and revise it where necessary to ensure its continued suitability, adequacy and effectiveness in implementing the ASC Requirements.
How Do I Interpret This Requirement?
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The UoC’s management system review should provide the opportunity to assess its suitability, adequacy and effectiveness in continuously ensuring conformance with the ASC requirements.
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The review should consider:
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Progress and effectiveness of changes implemented following the previous management review.
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Financial and personnel resources necessary to maintain the management system.
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Changes in the internal and external context of the site which may give rise to previously unanticipated issues.
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Performance review since the previous management review.
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Internal and external audit outcomes.
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Grievances raised.
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Progress towards longer-term ASC targets, e.g. an increase in wage payments.
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Progress towards site commitments.
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A mechanism for employees’ feedback on the effectiveness of the management system
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The outcome of the review should include addressing any need for changes and opportunities for improvement in the management system, which is documented and communicated to relevant employees for implementation.
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Evidence of Implementation
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Records:
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of the review and its outcomes.
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meeting minutes.
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Auditors Should Confirm
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Review is conducted at least annually.
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Records.
Indicator 1.2.3
Requirement
The UoC shall ensure that relevant employees have the necessary skills and training to implement the ASC Requirements.
How Do I Interpret This Requirement?
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At the site, it should be clear who is responsible for what tasks and management should ensure all employees are competent for the role that they will be carrying out. Employees should have:
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Knowledge,
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Experience,
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Training (theory and on the job),
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Capacity, and
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Decision-making permissions.
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‘Relevant employees’ and ‘necessary competencies’ refer to an employee’s function and area of responsibility:
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For example, a Health and Safety Manager is able to carry out and regularly update the Health and Safety risk assessment and define mitigating measures, but might not have the experience to treat injuries. Or the person responsible for first aid can take immediate action in the case of an injury and has access to and an overview of all first aid supplies, but might not have the experience to carry out a Health and Safety risk assessment.
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Evidence of Implementation
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Job descriptions of all employees.
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Organisational chart with clarity on who is responsible for what.
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Records and documents of training.
Auditors Should Confirm
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Employees and management are clear on their roles and responsibilities in the implementation of ASC Requirements.
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Employees have the necessary competencies, knowledge and experience to implement the ASC Requirements.
Indicator 1.2.2
Requirement
The UoC shall appoint at least one member of management responsible for the implementation of the ASC Requirements.
How Do I Interpret This Requirement?
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The responsible person may be one person or several persons, covering the wide range of issues addressed by the ASC Requirements.
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For example, a human resources manager may be responsible for the requirements on labour rights and working conditions, and a fish health and welfare manager may be responsible for the requirements on fish health;
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senior management should be responsible for seeking more specialised knowledge when needed.
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The responsibility should be embedded in the organisational structure documentation to ensure clear accountability.
Evidence of Implementation
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Records:
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that evidence the responsible person(s) were designated by the management.
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role description of the responsible person(s) for the implementation of ASC Requirements.
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Auditors Should Confirm
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The management designated responsible person(s) for the implementation of the ASC Requirements.
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through records and interviews with employees and the management.
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Role description of the responsible person(s) for the implementation of the ASC requirements.
Indicator 1.2.1
Requirement
The UoC shall develop, implement and maintain a management system to support the implementation of the ASC Requirements that is appropriate to the size and complexity of the UoC.
How Do I Interpret This Requirement?
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The scope of the management system should suit the operation that it is designed for. For example:
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A site situated at a remote distance at sea might not need additional elements in the management system to work with communities, or
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A site operating a RAS system might not need additional elements in the management system to manage the risks of escapes.
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A management system should include:
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Policies: explain why a site is operating in such a way.
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they can be beneficial for employees to understand their rights and duties.
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it is not necessary to have a policy for every topic in the ASC Farm Standard and sometimes topics are grouped together in one policy.
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for example, forced labour, child labour, discrimination, collective bargaining and freedom of association and others can all be addressed together through the human rights policy.
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policies are most valuable for topics which are not straightforward in the local context.
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for example, where employees have an inconsistent or incomplete understanding of an issue, a policy might be needed.
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Procedures: explain how a site operates in a certain way and specify how to put policies into operation to ensure the outcome intended.
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Records: provide an essential source of information for both internal self-assessments and external audits, documenting that policies and procedures have been followed in specific instances.
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sites can use recording templates to guide the user through all of the steps of a record and provide accurate information in a set format.
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records should be adequately maintained and controlled, including ensuring only up-to-date versions of documents are used.
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Evidence of Implementation
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Documents of the management system, including policies, procedures and records.
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Evidence that demonstrates management’s ownership of the management system (see ???).
Auditors Should Confirm
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Existence of up-to-date policies, procedures and records.
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Management’s ownership of the management system:
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attendance at management reviews (see Indicator 1.2.4).
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active role in the development, implementation and maintenance of the management system.
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demonstrable during interviews with the management.
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Useful Resources
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The ISO 9001:2015 management system standards: https://www.iso.org/management-system-standards.html
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Plan Do Check Act Cycle: https://asq.org/quality-resources/pdca-cycle
Indicator 1.1.2
Requirement
The UoC shall comply with all applicable legal requirements, including those relevant to the Criteria within the ASC Farm Standard.
How do I interpret this requirement?
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‘Applicable legal requirements’ refers to any type of law or regulation that is relevant to the scope of the ASC Farm Standard.
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The UoC should be responsible for:
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having a good understanding of laws and regulations including their applicability to the local context; and
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facilitating any inspections by authorities.
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Evidence of implementation should be maintained, e.g.:
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A register for legal compliance, for example, listing:
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relevant applicable laws and regulations, including, for labour-related laws and regulations, those within the home country of any migrant employees; and
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compliance status, and any future actions needed to remain complaint; and
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any measures needed to correct potential non-compliance with a law or regulation.
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Certificates or other records to confirm compliance with legal requirements.
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Documented outcomes and records of any inspections by authorities.
Auditors should confirm:
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Existence of any legal documentation, outcomes of inspections, or records kept by UoC to demonstrate legal compliance.
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Management understands the legal context in which they are operating.
Useful Resources
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The International Labour Organization (ILO) maintains NATLEX (www.ilo.org/dyn/natlex), a database of national labour, social security and related human rights legislation across 196 countries and more than 160 territories and subdivisions. NATLEX is a free source of information for all users.
Indicator 1.1.1
Requirement
The UoC shall hold all applicable legal licences and permits.
How do I interpret this requirement?
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The UoC should be responsible for:
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Having a good understanding of local licensing and permit systems that apply.
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Obtaining all necessary documentation for siting, constructing and operating their facilities. Examples of these can include:
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business/operational licences,
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land deeds,
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leases or concession agreements,
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construction permits,
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water use permits,
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effluent permits,
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landfill operation permits,
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fire safety certificate,
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building fitness certificate,
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permit or licence to store fuel (such as oil and/or gas),
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licences or permits to house workers in provided accommodation,
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changes to labour legislation, regulations and laws are reflected in workers’ contracts.
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Paying attention to:
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pending licence renewal for applications of, e.g. relocation of sites, biomass increase;
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conditions set as part of the licence/permits.
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Evidence of implementation should be maintained, e.g.:
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Up-to-date documentation for siting, constructing and operating, including any applications in progress.
Auditors should confirm:
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Documentation confirming required legal licences and permits are in place.
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Conditions required as part of business licence applications are adhered to. For example:
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In some parts of the world, a business licence is not issued unless mandatory certificates of building fitness and emergency preparedness for natural disasters are obtained.
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Useful Resources
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Assistance in determining necessary licences and permits can be sought from governmental agencies dealing with business and the environment and communities.
