5 March 2021

SAI Responses

• Have you been able to conduct audits/certifications/impact assessments in Xinjiang in recent years?  

There are no current SA8000 certifications in Xinjiang and have been no SA8000 audits in Xinjiang in recent years.  

• What possible problems have you encountered during audits/certifications/impact assessments in Xinjiang? 

Because there are no recent SA8000 audits in Xinjiang, we do not have first-hand examples of possible problems with auditing in this context. However, SAI and our accredited CBs have been aware of possible challenges to auditing in the region and we have classified Xinjiang as a high-risk location for the purposes of SA8000. Accredited CBs (the third-party audit firms that conduct SA8000 audits) are required to be aware of regions and industries that represent a high risk for labor abuses and are held to a high standard for due diligence in those cases—likely contributing to the lack of SA8000 activity in the region for several years.  

• How do you assess the migrant situation at manufacturing facilities outside Xinjiang, i.e. how do you ensure that the migrant experience is taken into account?  

The experiences of migrant workers are included as a matter of course in all SA8000 audits. Our procedures require that audit team members understand the make-up of a company’s workforce before the audit, so they can include a good, representative sample in worker interviews and tailor their questions to address labor concerns specific to those groups. This includes not only identifying that migrant workers are present, but also their places of origin (e.g. national or international), their hiring and recruitment process, conditions of employment, etc. Auditors are also required to consult with relevant external stakeholders as part of the audit process, especially groups familiar with migrant worker concerns in the region.  

• What indicators do you use to identify workers from Xinjiang who have been sent by the government?  

In China, SA8000 auditors have received specific instructions to be aware of issues and concerns related to Uyghur workers outside Xinjiang. Auditors look for indicators like discrepancies in pay, irregular hiring processes, visual and interview response cues, and the presence of vocational training programs within an organization to identify the possible presence of workers from Xinjiang.  

• To what extent have you integrated the type of questions listed in:

1. the Responsible Sourcing Tool’s Supplier Self-Assessment, in order to capture forced labor in interviews with company management? 
2. the Responsible Sourcing Tool’s Migrant Worker Interviews, in order to capture forced labor in interviews with migrant workers?  

The SA8000 Standard uses a management-systems approach and assesses the organization’s management system maturity overall and as it relates to managing labor performance elements of the Standard, including forced labor. The types of questions asked in these tools have long been part of the SA8000 system and SAI guidance and training for auditors. SA8000 auditors seek to answer exactly these types of questions throughout the audit process, including the organization’s self-assessment and the auditor’s review of policies and procedures, review of records and documentation, site observations, and interviews with workers, management, and external stakeholders. 

• How do you ensure that migrants can participate in interviews without outside interference or pressure? 

If migrant workers are present in an organization, they must be included in worker interviews for SA8000 audits. The same procedures to ensure confidentiality and comfort with the interviewer apply to both migrant and local workers, including: Conducting interviews in a private location, separate from manager observation and interference, where the interviewee is comfortable and cannot be overheard; 
Including both male and female auditors on the audit team to ensure workers can speak with someone of their own gender; 
Including adequate language skills on the audit team to conduct interviews with both migrant and local workers in their native languages.

If the CB does not have adequate internal language skills for a given audit, they may hire independent translators. We are not aware of examples where SA8000 audits have included an assigned state translator in China or elsewhere. 

• How do you work with translators in relation to migrant workers? Do you have your own translators covering all relevant languages (including Uyghur) or are you assigned state translators?  

See previous.