As, Compliance is most essential term in RMG industry, it is required to maintain in sustainable way, to increase Global Image & Recognition for the Performance, which requiring for doing business in long term. This presentation has been stating on how company can co-relate the compliance practices with the Sustainability. Any suggestion/guideline would be highly appreciated.

1. How to Develop Compliance with Sustainable Practice
in
RMG Industry
Presented by
1
Amatun Noor
MBA (HRM)
Working on Apparel Sector since 2010

2. Overview
2
As Bangladesh is 2nd largest Garments Exporter country in the world and
has been contesting with other rivals (i.e. – China, Vietnam & Myanmar), it
demands to develop infrastructure in RMG industry with sustainability to set
long term goal to survive against the rivals.
Bangladesh has been facing challenges on the issue of Raw Materials, Power
& Energy Resource, Lead-time, Price Competitiveness, Skill Workers, Working
Hour, etc. Now international buyers are creating pressures on the issue of
maintaining Compliance. Before placing the orders in the factory buyers are
auditing the factories to assess the Labor standards, Employment Conditions,
Work Environment, Occupational Safety & Health, Industrial Relationship and
Management System exactly to the Rules and Regulations or not.
So, it is the big challenge to satisfy buyers during Audits complying with
International Labor Standard(s), Country Law(s) & Rule (s) as well as Buyer
Standard(s). So there is no alternative to develop/establish Compliance with
Sustainability in the work place.

3. What is Compliance?
3
- An affirmative Indication or Judgment that the supplier of product or
service has met the requirements of the relevant Specifications, Contract
or Regulations also meeting the Requirement.
- In “ISO” term Compliance to Regulations, compare with Conformance; so
that, Enterprise/Facilities/Industries of all sizes can ensure supplier,
Operational & Regulatory Compliance to minimize the risk, increase
opportunity and realize the full potential of agreement, transaction and
contracts. Or,
- To comply with Country Laws, Rules & Regulations and Govt. Gazette,
Buyers Code of Conduct & International Standards.

4. Background of Compliance
4
- Since July 1995, there was a joint collaboration program & MOU signed
with ILO, BGMEA & Bangladesh Government.
- The program was one of component of Compliance, which is “Child Labor
Elimination from the RMG Industry”.
- Then another MOU signed at January 2001 on WIP (Workplace
Improvement Plan) in RMG Industry.
- Then Compliance journey had started.

5. What is Sustainability?
5
- The ability to be maintained at a certain Rate or Level.
- Sustainability is the endurance of systems and processes.
- The ability to continue at a particular level for a period of time.

6. Why Sustainability is Important in Compliance?
6
- Long term Business (Continual Order)
- Increase the Business Volume
- Buyer Satisfaction & Good result in the Audit
- Avoid unnecessary penalties from the Buyer due to lack of Compliance
- Reduce Employee & Worker’s Turnover Rate
- Avoid workplace Incidents & Accidents
- Improve Quality of Product & Increase Productivity
- Reduce Business Costs
- Global Image & Recognition for the Performance
- Good Public & Community Relations
- Good Government & Industry Relation

7. Core Actions for Sustainable Compliance
7
- Top Management Commitment
- Sufficient Knowledge of Mid Management or Responsible Persons
- Well Planned construction of the factory building
- Process of identification of risks that an organization faces and advise on
them (Identification)
- To Design & Implement controls to protect an organization from those risks
(Prevention)
- To Monitor & Report on the effectiveness of those controls in the
Management of an organizations exposure to risks (Monitoring &
Detection)
- To resolve compliance difficulties as they occur (Solution)
- To advise the business on rules and controls (Advisory)

8. How does Compliance will be Practiced &
Sustained in the Work place?
8
Plan
Do
Check
Act
Compliance is not
CSR, rather than it is
the basic mandatory
requirement of
deriving Business

9. Plan
9
- Set the Goal  “Workplace to be fully Compliant”
• “Top-Management’s Commitment” to be required.
- List the tasks to reach to the Goal -
• Determine the External & Internal Issues, Interested Parties (i.e. –
Worker, Stakeholder, Bank, Shareholder, etc.) and the Scopes.
• Set COC for the company to meet Compliance
Requirement/Standard.
• Determine the Legal Requirements & Other Requirements (i.e. -
Country Law & Rule, International COC, Buyer Standard, etc.
(Annex: 1).
• Collect all License(s), Certificate(s) & Permit(s) to meet legal
requirements (Annex: 2).

10. Cont.……..
10
- List the tasks to reach to the Goal -
• Develop Policy & Procedure based on the Compliance Requirement
/ Standards (Annex: 3).
• Analyse the Risk(s) & Opportunity(s) to meet the Compliance
Requirements.
• Set the Control Measures.
 Sources of Law, Rule, Gazette, etc. -
 www.http://bdlaws.minlaw.govt.bd/
 http://www.parliament.govt.bd/
 http://www.ilo.org/
 http://www.bgmea.com.bd/
 www.http://boiler.govt.bd/

11. Cont.……..
11
- Company Policy(s) & Procedure(s) –
• Those reflect how to Execute / Maintain Compliance Standards in the
company (Annex: 2).
• To be developed complying with Country Law(s) and Rule(s) &
Regulation(s), International Standards as well as Buyer COC.
• Define Company Principles & Commitments, Objectives, Target Group,
In-line Tasks (How to execute the policy) & Routine, Responsible
Person for each specific task and Time-frame.
• To be communicated to all Workforces; both Worker & Management.
• To be Evaluated & Reviewed as regular basis (At least Annually) to
identify the Short Comings, for Remediation as well as next Action
Plan.
• To be developed in local language.
• Top Management Approval is mandatory.

12. Cont.……..
12
- Risk & Opportunity Analysis & Control Measures –
• Identify the probable Risk Factors for any violation as well as the
Opportunities for the implementation of any standard.
• Preventive & Control Measures to be defined against all Risk factors as well
as to be implemented as regular basis.
• Responsible Person to be designated & accountable for each actions.
• Risk Analyses to be conducted based on -
 Social & Labor Standard  Twice a Year
 Occupational Health & Safety Standard  Twice a Year
 Fire Safety & Emergency Situation  Twice a Year
 Environmental Standard  Twice a Year
 Security Standard  Quarterly a Year
• Training to be provided; both Worker & Management.
• Use local language for Risk Analysis.

13. Do
13
- All operations to be led in line with Compliance as per company Policy
& Procedure).
- “Organizational Structure” & “Chain of Command” to be set-up.
- Responsible Person to be made as Accountable with specific Role &
Responsibility for the implementation of Compliance standard.
- All Guidelines/Decisions about to be communicated to the Workforce
through –
• Meeting
• Training
• E-mail
• Announcement
• Notice/Circular/Letter, etc.

14. Cont.………
14
- “Team Effort” results Good Compliance .
- All depts. need to Cooperate & take Responsibilities to ensure
Compliance in the workstation.
- Compliance Activities to be Supervised & Directed as regular
basis, not only for emergency or audit.

15. Cont.………
15
- Training & Awareness:
• To be provided both; Management personnel & Worker (Annex: 4)
which is essential to –
 Make the Workforce familiar with Compliance Culture.
 Develop Skill & Performance of the workforce.
 Lead all operations in line with Compliance.
 Communicate new Standards/Changes to the workforce.
 Meet the Buyer Requirements.
• Emphasize on Management training who drives the operations in the
workplace.
• Training is not Expenditure, rather than it is the key of Development &
Sustainability which are essential requirement for long-term business.

16. Cont.………
16
- Training & Awareness:
• Training & Awareness to be provided through –
 Classroom Session
 Audio & Video
 Announcement (by PA system)
 SOP (Standard Operating Procedure)
 Poster, Signage, etc.
 Audio & PA system are more effective tools for refresher training, as
production time is not consumed by these techniques.
• Need Analysis & Pre-Assessment to be conducted among the
workforce to determine which type of training is required.
• Post-Assessment to be conducted to measure the impact & effectivity
of the Training & Awareness.

17. Cont.………
17
- Different “Committee” may be formed to lead Compliance Activity which
also required as per Country Law & Rules as well as Buyer end:
• Make more functional the Committees through -
 Frequent Meeting
 Defining Role & Responsibility
 Actions with specific Time-frame
 Monitoring & Tracking (Actions are implemented or not)
 Evaluation

18. Cont.………
18
- Committees as per Country Law & Rules and Buyer Requirement:
• Participation Committee
• Safety Committee
• Recruitment & Selection Committee
• Anti-Harassment & Abuse Committee
• Anti-Discrimination Committee
• Grievance Redress Committee
• Machine Safety Committee
• Environmental Management Committee

19. Cont.………
19
- Basic Compliance standards -
• Working Hour & Overtime
• Wage, Overtime Premium, Bonus, Compensations, and On-time
Payment
• Yearly Increment & Promotion
• Leave Facility & Annual Leave Encashment
• Child Labor
• Force Labor, Bond Labor, Indentured Labor, Prison Labor
• Discrimination
• Harassment & Abuse
• Freedom of Association & Collective Bargaining (PC Activity)
• Grievance Mechanism
• Termination of Employment including Final Settlement

20. Cont.……..
20
- Basic Compliance standards -
• Occupational Health & Safety -
 PPE & Safety Precaution
 Drinking Water
 Structural Safety (i.e. - Building/Floor Lay-out, Crack, Occupancy
Load, etc.)
 Fire Safety
 Locking Device
 Exit. Stair & Passage Way
 Fire Protection Arrangement
 Emergency Action Plan & Contact Number
 Electrical Safety
 Medical Treatment

21. Cont.……..
21
- Basic Compliance standards -
• Security –
 Periphery Security
 Physical Security & Access Control
 IT Security
 Personal Security
 Shipment Information Control
 Export Logistics
 Contractor Selection & Control, etc.

22. Check
22
- Compliance Activities to be monitored through –
• Different Information / Data –
 Accident & Injury Log
 Grievance & Disciplinary Action Record
 Absenteeism Record
 Workforce Turn-Over Record
 Exit Interview Record
• Internal Compliance Audit -
 Social & Labor Standard as well as Occupational Health & Safety 
At least Monthly basis
 Environment Standard  At least Monthly basis
 Security Standard  Quarterly basis

23. Cont.………
23
- Compliance Activities to be monitored through –
• Internal Compliance Audit reports, conducted by the 3rd Party or
Buyer
• Survey among the Workforce (At least 50% of the total workforce)
• Survey among the Community (Best Practice)
• Open-door Conversation
• Meeting (Especially with the different Committees of the workplace)
• Help Desk & Hot-line Number
- All results to be accumulated and documented in the form of “Report”
for the next course of action (Evaluation & Action Plan).

24. Act
24
- Analysis & Evaluation of Monitoring Report
- Root Cause Analysis
- Action Plan based on the Severity & Needs –
• Initiating to eliminate all NCs ASAP.
• Increasing awareness among the workforce.
• Revising Company Policy-Procedure, as per previous feed-back.
• Restructuring Responsible Person, Job Responsibility, Accountability,
etc. (if required)
- Setting Plans for the next.

25. What is Compliance Audit?
25
Compliance audit is
 A comprehensive review of an organization's adherence to regulatory
guidelines.
 An official inspection of the factory processes and performance based
on standards & specific guidelines by an individual body.
 Like doing a survey: a neutral point of view. The objective is to identify
the compliance & non-compliance to some specifications, standards,
contractual agreements or other criteria.
 Made of observation which inspects the equipment and processes
based on the written procedures.

26. Cont.………
26
 Audit’s important output is the non-conformity list (Minor, Major,
Critical, Zero Tolerance, etc.).
 It allows to define action plans to improve the implemented system.
Audits can be internal or external.
 Audit result can be Unacceptable, Acceptable, Good, Need
Improvement, Satisfactory, etc.
 Audit result can be categorized based on country law, international
standard(s) as well as buyer standard(s).

27. Challenges of Factory Management
27
- Lack of strong Commitment from the Top Management regarding
implementation
- Investment for new requirements (Expenses)
- Lack of knowledge of Designated person on compliance
- Excessive Working Hours & Off Day & Festival holiday works
- Minimum Wages
- Trade Union
- Improper Organogram & Responsibility
- Make a Culture of Standard Compliance
- Insufficient support of compliance requirements from Top mgt.
- Safety Equipment Neglected

28. Cont.………
28
- Lack of effective Training & Awareness
- Some Safety Requirement of Alliance & Accord standard, such as
• Sprinkler
• Fire Door maintenance
• DEA
- Some License, Certificate & Permit, such as –
• Environmental Clearance Certificate
• Building approval from Rajuk if under DAP
• BERC Certificate from Bangladesh Energy Regulatory Commission
• Waiver Certificate from Bangladesh Explosive Department (if more
than 2500 liter chemical stored)

29. Case Study
29

30. Case: 1
30
Renaissance Group entries in RMG business as Knit manufacturer with 55
lines in March, 2015. The owner made a 8 storied building in his own land.
After completing all set-up, the factory starts production with 2500
workforce (both management staffs & workers) and declared to the buyer in
March, 2016. In the first initial audit, facility achieved “Good” rating from the
buyer; with no ZT or Major issue, only below 3 minor issues raised by the
auditor -
- Needle Guard found missing in 3 sewing machines out of 15.
- Found soap inadequate in the male toilet.
- Cutter found untied in 5 sewing machines.

31. Cont……..
31
1 year later, follow-up audit conducted at the same facility by the same audit
team where found 1 ZT & 4 Major Issues and audit result become
Unacceptable as well as another new audit required to arrange within short
time to get the new order. The issues are –
- Aisles found block
- Locking devices have been using
- Fire Alarm is non-functional
- No secondary maintained for chemical container
Question
Why this situation is occurred and what is the root cause behind it??

32. Case: 2
32
In June, 2016, 1 Band-Knife Operator of Cutting Section of Renaissance Group
has died, suffering from Tetanus.
At the time of investigation, it is found that, 11 months back, his 1 finger
(Pointer) had cut-off by Band-Knife machine during working. He did not use PPE
in that time and after the incident he took medical treatment but did not take
any vaccine.
Generally, operators do not use PPE during working in this machine, as no PPE is
provided by the management. On the other hand, there is no arrangements for
the proper medical treatment, at the facility.
In the investigation, Management stated that, they did not guess the probability
of this type of incident.
Question
Why this situation is occurred and what is the root cause behind it??

33. Annex: 1
List of Law, Rule & Regulation, International COC, Buyer Standard, etc.
33
- Bangladesh Labor Law – 2006, Amendment – 2013 & Bangladesh Labor
(Amendment) Law – 2018
- Bangladesh Labor Rules – 2015
- Bangladesh National Building Code – 2006 and ACCORD / Alliance
Standards as well as NFPA Guideline
- Building Construction Act – 1952
- Statutory Regulatory Orders (S.R.O) – 109, Act – 1999, published on 25th
May
- Dhaka Mahangar Imarat Nirman Bidhimala – 2008
- Chittagong Imarat Nirman Bidhimala – 2008

34. Cont.….....
34
- Circular on Building Permit on 19th August – 2010, Ministry of Housing &
Public Works/Pari – 1 / Occupant – RMG 42/2007/256, Circular no.
Ministry of Housing & Public Works/Pari – 1/Occupant-RMG 42/2007/302,
dated on 25th November – 2008
- Circular on Removal of Temporary Tin shade from Rooftop of RMG Factory
Buildings (Ref: BGMEA Letter # BGA/Safety/18000/2011/28180, dated on
28th December – 2011
- Circular on 19th April – 2013_RAJUK_Building Permit inside Detailed Area
Plan (DAP)
- Fire Service & Civil Defence Act – 2003
- Fire Service Rules – 1961 & Amendment Gazette – 1999
- Fire Resist & Extinguish Act – 2003

35. Cont.….....
35
- Fire Prevention & Dousing Act – 2003
- Boiler Act – 1923
- Boiler Rules – 2010
- Electricity Act – 1910 & Electricity Rules – 1937
- Petroleum Act – 1934
- Gas Cylinder Rule – 1991
- Pressure Vessel Rule - 1995
- Explosive Act – 1884 & Explosive Rule – 2004
- The Bangladesh Environmental Conservation Act –1995
- Narcotic Control Act – 1990

36. Cont.………
36
- Narcotic Control Rule - 1990
- The Environmental Conservation Rules – 1997
- Ecologically Critical Area Conservation Rules – 2010 (12 areas in
Bangladesh like, Coxbazar, Gulshan, Baridhara Lake, Sundarban, Kuakata,
Lawachara, etc.)
- Bangladesh Biological Diversity Act – 2012
- The Noise Pollution Management Rules – 2006
- The Medical Wastage Disposal Rules – 2008
- ZDHC (Zero Discharge of Hazardous Chemical) Standard
- Acid Control Act – 2002
- Custom Act – 1969

37. Cont.………
37
- Company Act – 1994
- Stamp Act - 1899 & Amendment – 2012
- ILO Convention
- International Standard(s), i.e. - BSCI, SEDEX, ISO, WRAP, GOTS, OCS, GRS,
etc.
- Security Standards(s), i.e. - CT-PAT (Customs Trade Partnership against
Terrorism), SCS (Supply Chain Security), SCAN (Supplier Compliance Audit
Network), GSV (Global Security Verification
- Buyer COC & Company COC

38. Annex: 2
List of Licence(s), Certificate(s) & Permit(s)
38
SL Particular To be Collected from Remark
1
Certificate of
Incorporation
Register of Joint Stock Companies
& Firms of Bangladesh
One time
2
Memorandum of Article
of the Company
Register of Joint Stock Companies
& Firms of Bangladesh
One time
3
Trade License /Business
License
City Corporation
4 Factory License Factory Chief Inspector
5 Factory Set-up Permission
Register of Joint Stock Companies
& Firms of Bangladesh
One time

39. Cont.………
39
SL Particular To be Collected from Remark
6 TIN Certificate
National Board of Revenue,
Bangladesh
One time
7 VAT Registration
Customs, Excise & VAT
Commissioner3535, Dhaka
(Under National Board of
Revenue, Bangladesh)
One time
8
BOI (Board of Investment)
Registration
Board of Investment
9
BGMEA / BKMEA
Membership Certificate
BGMEA / BKMEA

40. Cont.........
40
SL Particular To be Collected from Remark
10 Bond License Bond Commissioner
11
Import Registration
Certificate (IRC)
Import & Export Control
Department of Bangladesh
12
Export Registration
Certificate (ERC)
Import & Export Control
Department of Bangladesh
13
Enrolment Certificate
(EPB)
Export Promotion Bureau
14
Certificate of Group Life
Insurance
Nominated Company from
BGMEA / BKMEA

41. Cont.………
41
SL Particular To be Collected from Remark
15 Building approval
Rajdhani Unnayan Kartripakkha
(Rajuk) / Local Government
Engineering Department (LGED)
One time
16 Machine Layout approval Factory Chief Inspector One time
17
Multi-Storied Building
Clearance Certificate
Civil Aviation Authority of
Bangladesh
One time
18
Multi Storied Building
Occupancy Certificate
Local Government Engineering
Department (LGED)
One time
19
Bonded Wire-house Set-
up Permission
Customs Bond Commissioner,
Dhaka
One time

42. Cont.………
42
SL Particular To be Collected from Remark
20 Fire Insurance for factory Any Group Insurance Company
21 Factory Fire License Fire Service & Civil Defense
22
License for Captive Power
Generation (CPP) /
Generator Set-up Permission
Bangladesh Energy Regulatory
Commission
23 Electrical Set-up Permission
Bangladesh Rural
Electrification Board
One time
24
BERC Certificate / Generator
Set-up Permission (Gas &
Diesel)
Bangladesh Energy Regulatory
Commission

43. Cont.………
43
SL Particular To be Collected from Remark
25
Waiver Certificate from (If more
than 2500 Liter chemical stored)
Bangladesh Explosive
Department
One time
26 Fuel Tank Usage Permission
Bangladesh Explosive
Department
27 Steam Boiler Set-up Permission
Office of The Chief
Inspector of Boilers
One time
28
Boiler Operator’s Competency
Certificate (If any)
Office of The Chief
Inspector of Boilers
29
NOC for the use of Thermal
Boiler
Office of The Chief
Inspector of Boilers
One time

44. Cont.………
44
SL Particular To be Collected from Remark
30 NOC for Water Extraction
City Corporation / Union
Parishad
One time
31 Waste Water Test Report
Nominated 3rd Party by the
Buyer
32
Environment Clearance
Certificate (ECC)
Department of Environment
33
Initial Environmental
Examination (IEE) report
Recognize 3rd Party (i.e. – Bureau
Veritas, SGS, Intertek Ltd. etc.)
One time
34
Environmental Impact
Assessment (EIA)
Recognize 3rd Party (i.e. – Bureau
Veritas, SGS, Intertek Ltd. etc.)
One time

45. Cont.………
45
SL Particular To be Collected from Remark
35
Air Emission & Noise
Pollution Test Report
Department of Environment /
Certified Company
36
Hospital Agreement (As per
Bangladesh Labor Rules –
2015)
Any Nearest Reputed Hospital
37
Working Hour / Shifting
Approval
Factory Chief Inspector One time
38 Electrical Certificate Power Distribution Board (PDB)
39 Drinking Water Test Report
Institute of Public Health (As per
Labor Rules – 2015)

46. Cont.………
46
SL Particular To be Collected from Remark
40
Electrician’s Competency
Certificate
Bangladesh Ministry of Power, Energy
& Mineral Resources
41
Folk Lift Operator’s
Competency Certificate
Bangladesh Road & Transport
Authority (BRTA)
42
Lift Operator’s
Competency Certificate
Lift Providing Company / Any
Recognize Institution
43 Doctor’s Registration Bangladesh Medical & Dental Council
44
Nurse’s Competency
Certificate
Any Reputed Organization
45 Acid License District Administration Office
46
Agreement with Waste
Collector
Any Collector having Business License
& Environment Clearance Certificate

47. Annex: 3
List of Policy & Procedure
47
- Employee Recruitment &
Selection
- Working Hour
- Leave
- Compensation & Benefit
- Increment & Promotion
- Loan
- Prohibition of Child Labor
- Child Labor Remediation
- Young Worker Treatment
- Employment Separation
- Grievance Mechanism
- Disciplinary Action
- Prohibition of Harassment &
Abuse
- Women Employee Treatment
- Disable Employee Treatment
- Prohibition of Discrimination
- Prohibition of Forced Labor
- Freedom of Association &
Collective Bargaining
- Occupational Health & Safety

48. Cont.………
48
- Fire Safety
- Emergency Action Plan
- Emergency Medical Service
- Personal Protective Equipment
(PPE)
- Lockout & Tag out
- Chemical Management
- Needle & Sharp Tool Control
- Product Safety
- House Keeping & Cleanliness
- Child Care
- Canteen
- Dormitory (if this facility is
available)
- Sub Contract
- Precarious
- Environment
- Waste Management
- Community Service
- Anti-Corruption
- Business Ethics
- Security

49. Cont.………
49
- Personal Security
- Physical Security
- Information Access Control
- Shipment Information Control
- Contractor Selection & Control
- Export Logistic
- ID Card
- Training
- Best Practices (if any)
- Document Control

50. Annex: 4
List of Training
50
- Induction Training at the day of
Joining
- Working Hour
- Leave Facility
- Compensation & Benefit
- Recruitment & Hiring Practices
- Grievance Mechanism
- Prohibition of Harassment &
Abuse
- Disciplinary Action Measures &
Communication Channel
- Prohibition of Discrimination
- Freedom of Association &
Collective Bargaining
- Prohibition of Child Labor
- Prohibition of Force Labor
- Treatment of Young Worker /
Employee
- Buyer Code of Conduct (COC),
International Standard and
UNGP (United Nation Guiding
Principles

51. Cont.………
51
- Anti-Corruption
- Business Ethics or Corporate Ethics
- Fire Safety & Emergency Response
(By Certified Authority & In- house
arrangement)
- Occupational Health & Safety
- First Aid & CPR (6 month’s
Certification Training & Regular
Refresher Training)
- Chemical Handling
- PPE & Safety Guard / Device
- Electrical Safety; based on NFPA –
70 (E)
- Boiler & Generator Operation
- Machine Operation & Safety
- Environmental Management
System
- Wastage Handling
- Housekeeping & Cleanliness
- Special Awareness on Work-place
Accident & Injury
- Factory Security Procedure

52. 52

53. 53