Validated Assessment Process

(VAP) Overview
VAP Operations Team
 Tool bled compliance pr ocess
ena
Risk Assessment: Risk Assessment Monitoring: Validated Assessment Corrective Action Planning (CAP)
Platform and Self-Assessment Process (VAP)
Questionnaire (SAQ)
• SAQ utilizes a standardized list of • A third-party service that provides an • Third party management of corrective
questions to assess labor, ethics, health, independent audit of a facility action plan
safety and environmental practices in • Benefits: • Individual management between
the supply chain • Provides companies a way to customer and supplier
• Benefits: identify nonconformances to the • Benefit:
• Raises awareness about the code • Ensures findings discovered during
importance of the code areas • Drives improvements in the audit are addressed.
• Enables companies to evaluate, management systems for labor,
improve and communicate their ethics, health, safety and
performance environmental conditions.
• Scopes and prepares audits
• Provides insight into where
capability building is needed.
More information at:
http://www.responsiblebusiness.or
g/standards/assessment/

2
Why choose the VAP?
 Value of the
VAP
Is your business effectively managing social, ethical, and environmental risks in your
supply chain?
Poor social and ethical performance in the supply chain can be damaging to your brand and shareholder value

The Validated Assessment Process (VAP) provides

companies assurance in identifying risks and
driving improvements and robust management Suppliers
systems for labor, ethics, health, safety, and
environmental conditions in the supply chain.
Member Stakeholders
Companies
Transparency is the key to a successful audit. The
Validated Audit model is contingent upon the supplier’s Validate
willingness to being open and honest about their social d Audit
Process
and environmental process and helps to build long
lasting relationships with customers and stakeholders.
 Defining the Validated Audit
Process
A VAP audit provides a unique combination of depth and quality assurance in an
independent, sharable qualified third party end-to-end audit service focused on
improving business practices.

Financial or Legal Due

1 to 3-day Checklist Audit RBA VAP Audit
Diligence Audit
• Closed (Y/N) questions • Systems based evaluation, • Evaluates legal compliance &
• Lack auditor checks on ensuring adequate depth (days operational risks to inform
systems, policy and/or data on-site based on size and investment and risk
triangulation complexity), worker interviews management
• Limited coverage and time on and data triangulation • Significant auditor day rates
site, resulting in limited depth • Management of the end to end
and # issues found process approved audit firms
• Challenging to share a and auditor certification
common audit report • Rigorous Quality Assurance
Proces
 The RBA Validated Assessment Process
Criteria
Foundation
Content
RBA Code of Conduct Labor

Local requirements Health & Safety

Environmental

Ethics
Management Systems for Labor,
Health & Safety, Environmental, and
Ethics
 VAP audit
protocol
LABOR HEALTH & SAFETY ENVIRONMENTAL ETHICS MANAGEMENT SYSTEM
A1 Freely Chosen B1 Occupational Safety C1 Environmental D1 Business Integrity E1 Company Commitment
Employment Permits/Reporting
A2 Child Labor Avoidance B2 Emergency Preparedness C2 Pollution D2 No Improper Advantage E2 Management Accountability
Prevention/Resource Reduction and Responsibility
A3 Working Hours B3 Occupational Injury and C3 Hazardous Substances D3 Disclosure of Information E3 Legal and Customer
Illness Requirements
A4 Wages and Benefits B4 Industrial Hygiene C4 Wastewater and Solid Waste D4 Intellectual Property E4 Risk Assessment and Risk
Management
A5 Humane Treatment B5 Physically Demanding Work C5 Air Emissions D5 Fair Business, Advertising & E5 Improvement Objectives
Competition
A6 Non-Discrimination B6 Machine Safeguarding C6 Materials Restrictions D6 Protection of Identity & Non- E6 Training
Retaliation
A7 Freedom of Association B7 Sanitation, Food and Housing C7 Storm Water Management D7 Responsible Sourcing of E7 Communication
Minerals
B8 Health and Safety C8 Energy Consumption & GHG D8 Privacy E8 Worker Feedback and
Communication Emissions Participation
E9 Audits and Assessments
E10 Corrective Action Process
E11 Documentation and Records
E12 Supplier Responsibility
Validated Assessment Process
(VAP)
 Risk
Assessment
Level 3
Integrity Standards of
VAP
APM managed Audit process, with option
for 4th party or internal RBA QM
Documentation of Full Scope of Triangulation
Findings and
Conformance Facility required to validate
all Conclusions
Ratings Audited
Auditor/Audit
Firm
Independent Minimum of two Certification
Payment Shadow Auditor auditors on site Auditee Survey
Program and
Processing at all times Performance
Review
 Benefits of the Validated Assessment
Process (VAP)

Capacity
Credibility Reduce Burden
Third-party assessment Collaborative approach to Building
against an industry-wide auditing to reduce the Audit findings are
standard burden on supply chain accompanied by good
companies from multiple practices
requests for social audits
15+ years program
management experience
Auditee ownership of Corrective Action Plan
Trained and approved audit report (to distribute (CAP) can be managed and
auditors, audit firms, as appropriate) shared online
processes and protocols
 VAP Roles and
Responsibilities

Audit Program Manager (APM) Audit Quality Manager (AQM)

● Strategy, Audit firm selection ● QC check & Ethical complaints
● Auditor training and certification ● Audit report management
● Supplier onboarding, audit contracts ● AQM CAP Management
● Audit scoping, scheduling, invoicing ● Audit Firm performance, report scorecard
● On-site emergency issues (technical)
Administrative Resouces
 How to leverage VAP within your
company
• Build awareness of VAP process in  Senior management
commitment
your organization  Train all employees

• Utilize the tools and resources  Local Training Resources

 Certified RBA Factory Lead
provided  Complete the SAQ
 Use provided materials

• Start assessing your own facilities and  Root cause analysis and
processes and training your people corrective action

• Make necessary
 Openly discuss with
improvements customers
 Utilize the Audit Quality
Manager
• Engage with your customers
 How to leverage VAP with your suppliers

1. Check to see if your supplier already has  Secure copy of report

a VAP report
If not,  Senior management
commitment
 Train all employees
1. Build awareness of VAP at the supplier level
2. Build supplier awareness of the VAP process and  Training Resources
Code of Conduct by providing links, suggestions for  RBA Certified Factory
Lead
resources, or sharing your experience  Complete the SAQ
3. Advocate supplier facility Self  Use provided
Assessment Questionnaires materials
 Root cause analysis and
4. Review and make necessary corrective action
improvements prior to
external audit based on assessment  Openly discuss with
results customers
5. Encourage suppliers to engage with  Utilize the Audit
Program
their customers Manager
6. Understand the audit process
 Audit
Costs
The price of the audit includes the following

Work Area Cost Contributors

Administrative: Contracts, invoices and business management
RBA Audit Program Management
Technical: Process management, coordination, quality assurance process,
Labor cost and expenses
Audit Preparation (scheduling, document review, etc.)
Third Party Qualified Audit Firm On-Site Audit
Report Writing
Rates vary by firm and expertise
Independent review of Audit report against VAP Protocol
Audit Quality Manager Auditor Scorecard for eachAudit
Corrective Action Plan Management initial guidance*

Costs: have already been negotiated, is the result a competitive comparison analysis and breakdown is
not provided because of legal/contractual restrictions
 Audit Man-
Days
Complexity of operations within the scope of
the audit. Size1 - number of workers at a facility
Criteria: dormitory, significant chemical
operations, intensive physical handling,
complex manufacturing operations, < 1000 workers 1000-5000 workers > 5000 workers
canteen, special operations, etc.

Low No listed complexity

criteria 4 days 8 days

Medium 2 listed complexity

criteria 4 days 6 days 10 days

High 3+ listed complexity

criteria 8 days 12 days

1. Size: employees include both hourly paid workers and salaried employees
2. Days: person days on site
Audit Scope
 Scope of RBA ValidatedAudit

• The Scope of the Validated audit is ALWAYS full site (all lines of business, all buildings and sections or
areas of a facility) in line with the RBA philosophy and mission to reduce audit fatigue and increase
audit report sharing focusing on industry sector improvements within the supply chain.
• The scope of the audit can be limited due to the following reasons ONLY:
– Site has more than 40,000 workers
– Some operations of the site are not within the industries covered by RBA membership
– A section of the site is non accessible due to proprietary or confidentiality reasons (within
industries covered by RBA membership)
– This is ONLY accepted if a written proof of objection from the customer of the restricted area
is
submitted and approved by the APM
– Different sections of the site have different management systems, management teams or there
is more than 5 km separation between the sections
– Operate under a different legal entity or license
 Type of
Auditee
Labor
Manufacturing Service Provider
Agent/Labor
Contractor
Any site of which the main
activity is to provide a service
such as design, call‐center, Any service provider who
security, canteen workers, provides any type of labor or
cleaning companies, staff to a site.
Any site of which the main gardeners.
activity is manufacturing,
assembly, repair, chemical,
significant mechanical or
distribution operation.
On site audit will happen at On site audit will happen at
office of service provider and office of service provider and
deployment site (if applicable) deployment site (if applicable)
Audit Activities
Initiating a VAP audit
 Process
Overview
The Validated Assessment Process follows a simple five-step process from the initial request for an audit to
corrective action management and the Closure Audit

Follow and
CAP
Report and Management
Quality
On-site audit Assurance
Process
Preparation
Initiate
request and
schedule
 Initiation

Auditee creates profile in RBA-Online, pays a fee and adds a facility (fee is per year, per facility)

Auditee completes and releases a facility Self Assessment Questionnaire

Auditee submit an audit request through RBA-Online and completes the necessary contracts

Contracts are executed, the RBA Audit Program Manager will scope, assign and cost the audit

RBA APM completes attachment C (costing approval / Scoping Agreement and sends to

Auditee
 VAP Contracts: The Auditee
Agreement

Purpose • Service Agreement

• Non-disclosure agreement

• Attachment B – Authorization to share report with RBA Members

Content • Attachment C – Scoping Agreement where Auditee pay for Audit

• Attachment D – Scoping Agreement where 3rd party pays for the audit on
behalf of Auditee

Revisions
• RBA does not accept changes to the standard agreements to ensure
consistency and fairness among all users of the Validated Assessment
Process
 Rescheduling and Cancelation
Policy
Auditors must book travel and schedule well in advance of the audit. In the event
that an auditee needs to cancel or reschedule an audit, the following penalties apply:

After contracting but no date agreed

16-20 business days prior to the audit

NO Charge
0-15 business days prior to
20 percent of the agreed the audit
auditor labor cost plus
incurred audit expenses plus Rescheduling - 30 percent of
350 USD (Rescheduling) or the agreed auditor labor
500 USD (Cancellation) cost plus expenses plus 350
USD (Rescheduling)
Cancellation - full auditor
labor cost plus incurred audit
expenses plus 350 USD
(Rescheduling) or 500 USD
(Cancellation)
 Preparation

Dates solidified Preparation Call Discussion of any Confirmation

observers

• Connecting • Lead auditor • Details shared • Of agenda and

email sent to and auditee logistics
auditee and • Approximately • 2 days before
lead auditor 5-10 days audit
before on-site
audit

Denied access or cancellation of an audit during the audit will result in penalty of the full
audit cost plus incurred expenses
On-Site
Assessment
Open Meeting

Facility tour

Worker interviews

Management
interview

Document review

Daily wrap up

Closing Meeting
 Auditee
Responsibilities
Provide resources to complete working hours template on Day 1.

Ensure all documents are ready for review by lunch time on Day 1. If not, audit will be canceled.

Assign representatives for Labor, Ethics, Employee Health and Safety (EHS) and Management Systems.

Ensure management representatives and workers selected for meetings and interviews are available at

the
times agreed

Ensure personnel, time and wage records for subcontracted workers in core operations are available by the end
of Day 1
 Audit Observer and Shadow
Auditors

• Purpose – Toprovide feedback to the RBA • Purpose – Toprovide feedback to the RBA on

Shadow Auditor
Observer

member on audit process and audit firm the auditors’ performance, competency and
performance. professionalism
• The Observer will not: • The Shadow Auditor will:
 Attend worker interviews  Attend worker interviews
Attend audit firm internal audit briefings and Attend audit firm internal audit briefings and
analysis analysis
Visit product areas that are not their own (in  Visit all product areas
cases where a customer in an observer).  Join individual management
Join individual management interviews (in Intervene if necessary, guide, advise an audit
cases where an observer is from a corporate firm
office).
Interfere, guide, advise an audit firm or
auditee in any way.
 Validated Audit
Report
• Auditee owns the report data and can distribute the report
as Auditee decides where Auditee pays for the Audit.
Ownership • Where a Third-Party Payer paid for the report, the
ownership of the report and distribution of the report
is subject to a separate agreement
• Companies listed in attachment B may receive a copy of
the report direct from the RBA APM and RBA-Online
Sharing • The Report is available in system and must be distributed
through the system
• Working hour template completed during this audit is
In the system an attachment
• Corrective Action Plan is managed in the system
 Report Writing
Timelines
Same Day 2 Days (2) 12 Days (14)
1 Priority 2 3
AF Initial
Finding
Submission
A
Draft
Notices
1 Days (15) 7 Days (22) 5 Days (27)
4 5 6
Sanitation Auditee Full AQM
Review Review Review

7 Days (34) 2 Days (36) 2 Days (38)

7 8 9
Revisions Report
Final Draft
Process Released
Corrective Action Plan
Management and Verification
 About the CAP
Process
Purpose
• Assess underlying root cause of identified findings
• Develop plan of action to address audit findings
• A fix during audit is still a finding but will be mentioned by audit firm as a “containment response”

Form
• Drafted using a standard excel template or RBA-Online

Sharing
• Must be shared with customers who are approved to receive the Validated Audit Report (VAR).
• Must entered into RBA-Online and approved by the assigned CAP Manager in order for a closure audit to be
scheduled

Closure
• Mandatory closure audit to validate that corrective actions have been implemented effectively.
• This is a separate audit and require costing approval (cost not included in this audit) and scheduling
 Managing the
CAP
AQM
Auditee Customer
Managed
CAP Managed Managed
A copy of the approved
CAP CAP CAP MUST be entered
Services Centrally managed It is possible to have into RBA-Online in order
process with only one several CAPs depending for any closure audit
RBA ValidatedCAP. on the customers. activity be scheduled
thru RBA.*

A copy of the approved

CAP MUST be entered
into RBA-Online in order *OUTSIDE THE SCOPE OF
Additional fee for any closure audit RBA
activity be scheduled
thru RBA.*

Communication on the
CAP and its progress will
be managed by the
APM with all customers *OUTSIDE THE SCOPE OF
listed in the “Auditee RBA
Approved Recipient
distribution list”
(attachment B).
 Value of the AQM Managed
CAP
Criteria AQM CMA AMA
CAP CAP CAP
Corrective Action for each finding in an audit   ?
Qualifies for RBA Recognition when verified through VAP Closure   
Audit
Requires closure as part of the VAP Process   
Highest level of independence for governments, customers 
and eco-label due diligence
Independent 3rd Party monitoring of CAP process 
Single CAP for multiple customers 
Collective input of multiple customers to drive CAP Closure 
3rd Party Quality Check of CAP to have the highest likelihood 
of successful closure audit
Statistically, highest CAP Closure rate 
 Closure Audit
Process
Follows same process as Mandatory within specific Triggered by the

Priority Findings

Major/Minor Findings
initial audit (request, timeframes customer or auditee
Verificatio

scoping, costing
Triggered by APM Typically all findings are
approval, scheduling, on
Any other findings the included in a single
site, report)
auditee has closed and is closure audit
Timing should be based ready to have verified, Best practice is a two-
upon the type of findings
n

especially those requiring step closure audit

in the initial audit (Priority, on-site verification, these • Remote verification
Major, Minor, Risk-of- can be included in a • On-site element
Nonconformance) Priority Finding Closure • Higher rate of success on-site
The closure audit should Audit. These need to be as items can be addressed
between the remote and on‐site
not occur later than 18 agreed on upfront with steps thus avoiding a 2nd, costly
month maximum from the APM on‐site element
receipt of the VAR

The focus of a closure audit is on the open findings but if the auditor encounters a code
violation then that must be recorded and becomes a new finding
 VAP Recognition
Program
Factories who successfully complete a VAP, closing audit findings and
verify closure through a VAP Priority Closure or VAP Closure audit, are
recognized with a certificate valid for 2 years from last day of initial  Must be VAP (no CMA/AMA)
audit.**  Must close all findings and submit CAP in RBA-Online
Platinum
 Must have VAP closure Audit
RBA Framework → Site Level RBA  Must have a score of 200
Recognition Minimum
VAP SCORE
• Social & Environmental Leader
Platinum 200  Must be VAP (no CMA/AMA)
• Closes All Audit Findings
 Must close Priority & Major findings, submit CAP in RBA-
Gold Online
 Must have VAP closure Audit
• Above Average Sustainable Factory  Must have a minimum score of 180
Gold • Closes Priority & Major Findings 180

 Must be VAP (no CMA/AMA)

• Sustainable Factory
Silver 160  Must close all Priority findings and submit CAP in RBA-Online
• Closes Priority Findings via VAP
Silver  Must have VAP Priority Closure Audit
 Must have a minimum score of 160

** Recognition expires when the audit expires * If there are Priority Findings in Forced Labor or Child Labor, the site is subject
to an unannounced audit over the next 12 months
Feedback Loops
 When can an auditee provide
feedback?
On-site
• It is preferred that auditees provide feedback to auditors during the on-site audit.
• This is the best time and most encouraged!

During draft review

• Through RBA-Online Discussion tab
• For review by QM and auditors

Post VAR Release / Any time

• Online at https://www.surveymonkey.com/r/RBAVGM

Post-Audit Survey (not related to findings)

• Available online: https://www.surveymonkey.com/r/LQ2CWWJ
 Guidelines for Providing
Feedback
• Select the most important • After VAR is closed, auditee
issues to dispute will have access to
• Additional information (not discussion tab for 7 days
available at the start of the • Feedback provided during
audit) will not be reviewed this time will be sent to APM
at this time • After this time, auditee must
submit through survey
monkey

Reasonable Timing
Resources
Please visit our website for more
information!

http://www.responsiblebusiness.org/vap/about-vap/
 Contact
information
• Contracting, Code and technical assistance
• [email protected] (RBA Audit Program Manager)
• Validated Assessment Process
• [email protected] (Hillary Amster, Director of Audit Operations)
• Invoicing and payment
• [email protected]
• General non VAP RBA information
• [email protected]
• Tools and Resources
• http://www.responsiblebusiness.org/standards/vap/