SMETA 7 Course – Requirement 0: Enabling an Accurate Assessment (English version)

Introduction

In ethical audits under the SMETA (Sedex Members Ethical Trade Audit) framework, transparency and collaboration from the audited site are fundamental to obtaining reliable results. For this reason, SMETA version 7 has introduced a new Requirement 0, “Enabling an Accurate Assessment,” which establishes clear expectations to ensure the audit can be conducted thoroughly, without hindrances, and with truthful information.

This requirement acts as an essential prerequisite: if it is not met, the integrity of the entire audit is compromised.

In simple terms, the audited site must facilitate the auditor’s work, not obstruct it, by ensuring access to accurate information and fostering an honest review environment. SMETA 7 explicitly defines the basic conditions that must exist during the audit, reinforcing transparency, accountability, and consistency in the process.

Below, we will explain each sub-requirement (0.A, 0.B, 0.C, 0.D) of Requirement 0 in depth, detailing what they entail, the topics they cover according to the official guidance, practical examples in manufacturing and service companies, common mistakes to avoid, and recommendations for proper compliance. This analysis is aimed at a broad audience—from compliance officers and plant managers to workers and consultants—using accessible yet professional language.

Disclaimer

This article is a personal interpretation and has no official connection with SEDEX or the SMETA framework. It was developed independently to guide and educate professionals, companies, and readers interested in ethical audits, based on my analysis and experience. SEDEX is the sole owner of SMETA, and the official, complete, and accurate information about SMETA 7 is found only in the documents and resources published directly by SEDEX (www.sedex.com). I strongly recommend always consulting SEDEX’s official guides to ensure compliance and accuracy in any practical application. By reading this article, the reader understands that it reflects solely my personal perspective and does not intend, under any circumstances, to represent, modify, or affect SEDEX’s position, guidelines, or reputation. My goal is to contribute to a general understanding of SMETA requirements in an educational and accessible manner.

Thank you for visiting my blog and for your interest in ethical compliance!

0.A: Unobstructed Audit with Authentic Records

Sub-requirement 0.A mandates that the company allows the auditor to conduct and complete the audit without any obstruction, providing access to all requested documents, individuals the auditor needs to interview, and all areas of the facility (including annex buildings and accommodations, if applicable), as well as supplying genuine and authentic records. In essence, the audited organization must fully cooperate: not deny access to information, hide parts of the site, or present falsified documentation. This ensures the auditor can accurately assess the company’s labor conditions and practices.

Issue Titles (Potential Findings): The official SMETA 7 guidance outlines several situations that would constitute serious breaches of sub-requirement 0.A. These include, for example:

Denying or fully obstructing the audit: When the audit cannot be completed at all due to intentionally obstructive practices (e.g., denying the auditor entry to the premises, access to key documents, or preventing worker interviews). In such extreme cases, the audit may even be canceled.
Partial obstruction of the audit: When the audit is only partially completed due to deliberate obstructions (e.g., the auditor is prevented from accessing certain areas, documents, or interviewing specific workers). Although the audit may proceed in other aspects, these intentional restrictions constitute a serious finding.
Attempts to interfere despite completing the audit: When, although the auditor manages to finish their work, management clearly tried to hinder the process (e.g., delaying the delivery of information, interrupting interviews, etc.).
Exclusion of worker representatives: If management refuses the participation of union or worker representatives in the audit, preventing them from interacting with the auditor.
Manipulation of worker testimonies: Evidence that workers were coached or pressured to provide misleading information to the auditor or were not allowed to express themselves freely.
False or incomplete documentation: Presentation of forged, duplicated, or deliberately incomplete records, especially if verified inconsistencies are found.
Inaccurate records hindering progress: Providing inaccurate or incomplete records in a way that significantly affects the auditor’s ability to advance their assessment.
Hiding workers: Evidence that the company concealed certain workers to prevent them from being interviewed or seen during the audit (e.g., removing them from the site that day).

These points reflect real situations that prevent an accurate assessment. If any of these occur, the auditor will report it as a breach of Requirement 0.A, which is typically considered a critical non-conformity in the audit.

Interpretation and Scope: To comply with 0.A, the company must understand that the auditor has the right to access all areas and set the pace of the site tour as needed. The scope of the audit must be appropriate: for example, if the audit was planned for a specific part of the operation but during the visit it is discovered that there are additional relevant areas or processes not declared, the auditor must be able to adjust and include them. If management insists on restricting the audit to an inappropriate limited scope, this will be considered a denial of access (total or partial) and documented as such.

Likewise, if the obstruction is total (e.g., the auditor is not allowed to enter the site, review essential documents, or interview anyone), it is recorded as “access fully denied,” and the audit cannot proceed. In such extreme cases, the auditor will issue a report stating that the audit could not be completed due to intentional obstruction. If the obstruction is partial (e.g., the auditor is prevented from completing parts of the process, such as certain interviews or areas), it is noted as “access partially denied.” In such cases, the auditor will conclude the audit with what could be reviewed and upload the corresponding report, highlighting the limitations encountered. It’s worth noting that even partial denial is considered serious: in addition to reporting it under 0.A, the auditor may raise additional findings in the specific areas that could not be verified due to lack of documentation or access.

Another critical aspect is the accuracy of records. If the company provides false records to any degree, the auditor will report the specific finding (“forged or intentionally incomplete records”) under 0.A. If the absence or inaccuracy of records is so significant that the auditor cannot conduct a meaningful verification, a finding of inaccurate records affecting the audit will be raised. In minor cases (small information gaps), these may be documented as non-conformities in the relevant sections, but if the information gaps undermine the integrity of the entire audit, a 0.A finding is warranted.

In summary, 0.A obliges the company to fully open its doors and records to the auditor. Any deliberate action to conceal, distort, or prevent access to information is considered a serious breach.

Practical Examples:

Manufacturing: A textile factory prepares for a SMETA audit. The auditor requests to visit the raw material warehouse and interview some employees from that department, but a manager claims the warehouse is “closed for safety reasons” and denies entry. Later, it is discovered that undeclared contractors were working there. This is a clear example of deliberate obstruction (0.A). Similarly, if the factory provides work hour records with suspiciously edited or inconsistent data (e.g., duplicating records to appear compliant with hours), it would be providing inauthentic documentation. Both situations violate 0.A, as they prevent an accurate assessment of labor conditions.
Services: In a call center company, during the audit, the compliance team insists on accompanying the auditor to all worker interviews and answers many questions on their behalf, attempting to control responses. Additionally, they only show payroll records for certain “selected” months, hiding others. These actions constitute attempts to manipulate the audit: restricting workers’ free expression and presenting biased information. The auditor could interpret this as workers being coached or intimidated and the records lacking integrity, leading to findings under 0.A.

Common Mistakes: Even without malicious intent, some practices can be interpreted as obstruction. Frequent errors include:

Not having all requested documents prepared, causing delays that may seem like deliberate hindrances.
Limiting the auditor’s access to certain areas “for production” or “safety” reasons without valid justification or prior agreement on exceptions.
Excessively interrupting or supervising worker interviews (which can inhibit honest responses).
Attempting to “spruce up” the factory just before the audit (e.g., moving temporary workers out of sight), which can raise suspicions of concealment if the auditor finds out.
Providing inaccurate information in the Sedex profile or at the start of the audit (e.g., declaring fewer employees than actual) thinking it will “simplify” the audit—this is often discovered and seen as an attempt to deceive.

Recommendations for Proper Compliance with 0.A:

Total Transparency: Ensure the auditor has free access to all areas, records, and people needed. Plan logistics to avoid restricting any zone; if there are sensitive areas (e.g., for intellectual property or hygiene), agree in advance with the auditor on how to handle them rather than denying access on the spot.
Authentic Documentation: Prepare documents (payrolls, schedules, health and safety records, etc.) in advance and review them to confirm they are authentic and consistent. Never alter or fabricate records; instead, focus on correcting real issues before the audit.
Communicate and Educate Staff: Explain to workers and middle management that they must cooperate openly with the auditor. Avoid “coaching” them with scripted responses; instead, encourage honest communication. The only preparation should be informing them about the audit’s purpose and reassuring them they can speak freely.
Availability During the Audit: Designate a company representative to accompany the auditor and promptly fulfill their requests (e.g., providing additional documents quickly). This person should be trained to understand their role is to assist, not cover up. Ensure someone is always available to address the auditor’s needs (avoid “absent managers” that delay the process).
No Retaliation or Intimidation: Foster an environment where no worker fears speaking out. Make it clear to supervisors that they must not interfere or retaliate based on what employees tell the auditor. Trust is key: if workers suspect they’ll be punished for telling the truth, they may stay silent or hide information, affecting the audit’s accuracy.
Verify the Sedex Site Profile: Update the Sedex Site Profile with accurate information (current and peak employee numbers, shifts, processes, valid licenses). This avoids unexpected discrepancies. Remember, the auditor will compare the on-site situation with the declared data; keeping the profile accurate streamlines the process and builds trust.

Complying with 0.A ultimately means fostering openness and honesty throughout the audit. A company that practices this not only passes the audit with fewer issues but also demonstrates to clients and stakeholders a genuine commitment to ethics and transparency.

0.B: Prohibition of Bribery or Coercion of the Auditor

Sub-requirement 0.B establishes that the company must not offer bribes, threaten the auditor, or attempt to induce them in any way to act dishonestly. This implies zero tolerance for any attempt to buy the audit’s outcome or unduly influence the auditor to conceal findings. Even subtle actions, such as inappropriate gifts or hints of rewards for “flexibility,” fall under this scope. Similarly, any form of threat or pressure (direct or veiled) toward the auditor is strictly prohibited. In summary, the audit must take place in an environment of integrity, where the auditor can report objectively without being compromised by incentives or coercion.

Issue Titles (Potential Findings): Given the critical nature of this requirement, the official guidance specifically identifies the situation that would violate 0.B: evidence that the auditor received (or was offered) a bribe or other incentive to misrepresent the truth. Any documented attempt by the company to corrupt the auditor—whether through money, high-value gifts, personal favors, or promises—would be reported under this sub-requirement. The same applies if it is confirmed that someone attempted to threaten the auditor (e.g., insinuating negative consequences if certain non-conformities are reported).

Interpretation and Actions: If during the audit the auditor perceives or receives an attempt at bribery or coercion, they will raise an immediate finding under 0.B and, per protocol, report it to the third-party auditing firm managing the audit. This allows the auditing firm to activate internal processes, as bribery not only violates the SMETA standard but also professional ethics and potentially the law. In such cases, the auditor may choose not to detail the incident in the main report delivered to the company (to avoid risking their safety or that of workers, especially if threats are involved). Instead, they would follow SMETA’s Sensitive Issues Process, preparing a confidential supplementary report not visible to the audited site. This mechanism exists to handle delicate situations like corruption or severe abuses appropriately. For the audited company, being involved in a bribery report would have severe consequences: beyond failing the audit, it would significantly damage its reputation with clients and could lead to legal action.

Practical Examples:

Manufacturing: In a manufacturing plant, on the day of the audit, the compliance manager accompanies the auditor. While reviewing documentation, the manager slides an envelope with cash toward the auditor “for additional expenses” and comments that “we can make a good arrangement” if the report comes out clean. This is a blatant attempt at bribery. The auditor, following protocol, rejects the envelope and reports the incident. The audit continues, but the 0.B finding will be recorded with evidence of the bribe offer, and the company will likely face consequences.
Services: In a cleaning services company being audited, the owner is anxious to obtain a favorable result. During the visit, they excessively try to please the auditor: they gift an expensive branded watch and say, “Consider it a token of appreciation.” Although not explicitly stated, this high-value gift during an audit can be interpreted as an attempt to influence. If the auditor reports it, it would be classified under bribery (0.B). In another case, suppose an executive intimidatingly tells the auditor, “It would be a shame if we lost our main client; I trust you’ll know what to omit from the report.” This insinuation constitutes a veiled threat. Either example would trigger a 0.B finding.

Common Mistakes: Fortunately, most companies avoid such blatant practices. However, errors or misinterpretations to avoid include:

Offering excessive courtesies to the auditor: e.g., costly gifts, lavish dinners, or personal benefits. While basic hospitality is normal (e.g., offering water or a simple lunch), going overboard can be seen as an attempt at bribery.
Inappropriate language or jokes suggesting payments: occasionally, a manager might jokingly say, “How much to pass us?” Such comments are entirely inappropriate, and serious professionals will document them.
Pressuring the auditor with phrases like “our business depends on this” or attempting to emotionally manipulate the situation. Any pressure compromises objectivity.
Not training security or reception staff: Imagine, without ill intent, a security guard prevents the auditor’s entry because they “weren’t notified” and asks for a “tip” to let them pass. This operational misunderstanding can appear as bribery or deliberate obstruction. It’s an avoidable error with proper preparation.

Recommendations for Proper Compliance with 0.B:

Integrity and Anti-Corruption Policy: Establish and communicate internally a strict policy against bribery. All staff, especially managers interacting with audits, must know that offering gifts, money, or favors to the auditor is prohibited. Reinforcing this point before an audit is crucial.
Train Key Staff: Ensure security, reception, and those accompanying the auditor are informed of the protocol. They should receive the auditor professionally, check their ID, etc., without making reckless comments or conditions. Courtesy is welcome; “kickbacks” are not.
Transparent Hospitality: If the company wishes to provide lunch or refreshments for the auditor (common and acceptable), do so transparently and modestly. Avoid material gifts. If corporate culture includes giving an institutional token, ensure it’s of minimal value and given after the audit concludes to avoid interfering with the process.
Never Threaten or Coerce: This seems obvious, but under stress, some may react poorly. Emphasize to managers that any form of threat is strictly prohibited. The auditor must feel safe and free to do their job. Creating a professional, respectful environment is the best approach.
Communication with the Auditing Firm: If staff are uncertain (e.g., about what constitutes an acceptable gift), consult the auditing firm or Sedex beforehand. Some guidelines allow promotional items of negligible value (pens, logo mugs), but not others. When in doubt, abstain or ask.

In sum, complying with 0.B means maintaining absolute integrity during the audit. The company must show it has nothing to hide or “buy” and accepts results ethically. This builds trust with clients: a company that doesn’t resort to bribes to pass an audit undoubtedly inspires greater credibility.

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0.C: Accurate Site Description and Truthful Sedex Profile

Sub-requirement 0.C requires the company to provide an accurate description of the site and maintain an exact Sedex Site Profile, as declared before or during the audit. In other words, basic information about the site—size, number of workers, activities, licenses, locations—must match reality. Any significant discrepancy between what is declared and what the auditor observes is considered an issue under this requirement. Why is this so important? Because audit plans are based on the information provided in advance. If a company reports incorrect data (due to negligence or intent), the auditor may not assess certain areas or properly gauge risks, compromising the audit’s accuracy. Thus, SMETA 7 emphasizes honesty and precision in the initial site information.

Issue Titles (Potential Findings): The official guidance highlights several typical situations where 0.C is not met due to incorrect or incomplete site information:

Number of workers different from declared: For example, if the company indicated in Sedex that it has 100 employees but 150 are found on audit day, or vice versa, if far fewer workers are present than the declared peak. A significant discrepancy in staff numbers (much higher or lower) indicates inaccurate information.
Inconsistent site description: If the description of operations, processes, or facilities provided to the auditor (or listed in the Sedex profile) does not match the reality observed. For example, the profile omitted an additional plant or a specific industrial process, and the auditor discovers it during the visit.
Informal or unregistered business: If the company’s facilities are informal or not legally registered, to the extent that authorities would struggle to locate the business physically. This may indicate misleading or incomplete registration information in Sedex (e.g., operating at a different location than declared or under an irregular legal entity).
Lack of valid licenses or permits: If the site operates without required, up-to-date licenses and permits (e.g., expired factory operating license, missing environmental permits). In practice, the Sedex profile should reflect that the company holds all mandatory permits; if the audit reveals otherwise, there is a significant inconsistency in the provided information.

All these situations compromise an accurate assessment because they mean the prepared or expected audit does not reflect the actual operation. The auditor will report these findings under 0.C, noting that the site description or profile was unreliable.

Interpretation and Considerations: If during the audit the auditor identifies that the site’s scope differs from what was confirmed during the planning phase (booking), they should attempt to adjust the plan to cover the actual scope. For example, if the company has an unreported second production plant, the auditor may extend the visit to include it. But if management refuses to adjust the scope or if it’s not feasible to expand it (due to time constraints, etc.), the auditor will raise a “denied access” finding under 0.A in addition to a 0.C finding for the inaccurate scope. In extreme cases, this could lead to terminating the audit before completion due to the discrepancy.

A critical point is when to conduct the audit in terms of activity level. SMETA 7 stipulates that audits must occur during high activity periods, i.e., when at least ~60% of the workforce is present, and preferably during peak production season (close to 80–100% of the staff). Auditing during low season with less than 60% of the usual workforce is not permitted, as it would not provide a representative picture. If it’s discovered during the audit that the number of workers present is below 60% of the maximum, the auditor must issue a non-conformity. Thus, accurately declaring the maximum number of workers and scheduling the audit date accordingly is part of 0.C. Auditing with too few people (e.g., during collective vacations) could be seen as a maneuver to “look better” and is explicitly prohibited.

Additionally, the site’s scope in Sedex and the audit must include all relevant parts of the operation under the same business license. The guidance indicates that the scope covers all business under the same license, within the same perimeter, or with the same management system, including warehouses, on-site subcontractors, waste management, etc., and even worker accommodations provided. If the company has, for example, off-site employee housing, it should be mentioned during the audit booking stage. Any scope limitations must be justified and agreed upon with Sedex in advance. In short, there should be no “hidden surprises” about what the audit includes.

Practical Examples:

Manufacturing: A footwear factory declares in Sedex that it employs 200 workers in a single shift and produces only at its main plant. However, when the auditor arrives, they find an additional undeclared night shift with extra workers, and part of the process (sole gluing) is done in an annex workshop not listed in the description. Additionally, the maximum capacity in peak season reaches 300 workers, but this was not reported. These inconsistencies (in employee numbers and facility description) violate 0.C, as the site profile was inaccurate. Another example: the factory’s municipal operating license expired four months ago. This means it operates without a valid permit—a 0.C finding because the company likely indicated in Sedex that it had all required permits.
Services: An industrial cleaning company prepares for its audit. In the Sedex profile, it reported 50 employees but omitted mentioning that it subcontracts 30 additional cleaners during peak season. On audit day, as it’s low season, only 20 workers are present (less than 40% of the peak total). The auditor notices the low staff presence and, upon investigation, discovers the discrepancy. This constitutes deliberate malpractice: scheduling the audit in low season to show fewer workers and possibly fewer issues, violating 0.C expectations. Additionally, suppose the company operates from two locations: an administrative office and mobile crews serving various clients. If the profile only mentioned the office and not the dispersed nature of the work, the auditor could consider the “site” description incomplete. Any significant undeclared element (another location, hazardous equipment storage, etc.) can trigger findings under this requirement.

Common Mistakes: Some situations where companies fail 0.C unintentionally include:

Not regularly updating the Sedex profile: Companies that uploaded their information years ago and have since had changes (more staff, new buildings, new processes) but don’t reflect them. This leads to discrepancies on audit day.
Declaring fewer workers by mistake or fear: Sometimes, to avoid higher fees or due to confusion, fewer employees are reported than actual, or temporary and subcontracted workers are omitted. This is a serious error, especially if intentional.
Forgetting minor licenses: Focusing on major permits (like operating licenses) but overlooking others required (e.g., fire department permits, environmental registrations, health certifications). While they may seem separate, all contribute to the site’s legal compliance.
Last-minute changes not communicated: For example, during planning, it was stated there would be X workers, but a week before the audit, a large order led to hiring 50 more people. If not reported, the auditor will see more people than expected, raising doubts.
Overlooking associated facilities: Forgetting to mention worker accommodations, canteens, daycare, or other related facilities provided by the company. If the auditor learns of these during the visit, it may seem like information was intentionally hidden.

Recommendations for Proper Compliance with 0.C:

Keep the Sedex Profile Updated: Review and update your Sedex Site Profile before the audit. Verify that the number of employees reflects both the current average and the peak in high season. Include all shifts, employment types (full-time, temporary, subcontracted), and any secondary sites within the audit’s scope. A good practice is to update this information periodically, not just when an audit is approaching.
Plan the Audit for a Representative Period: Schedule the audit date to avoid very low seasons. Ideally, it should be during normal to high activity (60–100% of the workforce active). If it must be in low season, inform the auditor and provide reasons, knowing that below 60% of the peak will incur a non-conformity. Transparency here is better than surprises.
List and Verify Licenses/Permits: Before the audit, create a checklist of all required legal permits (operating license, tax registrations, environmental permits, safety permits, etc.). Ensure they are valid and correctly named. Have copies ready to show. If any are in process, communicate this in advance. This shows diligence and avoids unexpected 0.C findings.
Communicate the Site’s Reality: If your operation has peculiarities (e.g., parts of the process at third-party homes or workers rotating between locations), discuss this with the audit team in the initial meeting. It’s better to over-describe the operation than omit key data. Include details in the site description provided to the auditor (typically at the audit opening) to complement the Sedex profile, ensuring the auditor has the full picture from the start.
Review SMETA’s Scope Guidance: Familiarize yourself with what a SMETA audit scope entails. For example, know that worker accommodations are included in the scope, as are satellite workshops within the same premises. This allows you to prepare those areas for the visit. If your company is part of a larger complex or shares facilities, consult with Sedex or the auditor on how to correctly delimit the scope before the audit.
Don’t Fudge Numbers: Honesty is the best policy. If there have been staff changes (e.g., recent layoffs), don’t hide it by asking workers not to show up on audit day. Instead, clearly explain the situation to the auditor. SMETA audits aim to reflect real conditions; any “staging” is usually detected and brings worse consequences than facing the truth.

By complying with 0.C, the company demonstrates reliability in the data it provides. This facilitates the auditor’s work and ensures the assessment focuses on how well the company meets ethical standards, rather than wasting time clarifying basic data. It’s an essential aspect of good information management in any compliance system.

0.D: Written, Approved, and Communicated Human Rights Policy

Sub-requirement 0.D requires the company to maintain a written human rights policy statement, approved at the highest management level, communicated to all staff, and with corresponding training for relevant personnel. In practice, this means the organization needs a formal document (e.g., a Human Rights Policy or Ethical Code of Conduct) expressing its commitment to workplace human rights, signed or endorsed by top management (General Directorate or equivalent). Moreover, it must not remain a filed document: it must be shared with all employees and training provided to those whose roles involve implementing these commitments. This sub-requirement adds a management system dimension: it evaluates not only actions during the audit but also the existence of a foundational corporate policy on ethics.

Issue Titles (Potential Findings): The possible shortcomings here boil down to two, per the official guidance:

No human rights policy or inadequate policy: If the company lacks a written commitment to human rights, or the existing one is clearly insufficient (e.g., too generic, not covering key labor aspects), it is considered a breach. The total absence is the most serious case, showing a lack of formal commitment.
Existing but incomplete policy: This occurs if the company has a human rights policy but fails to meet all established criteria: e.g., the document exists but lacks top management approval, hasn’t been communicated to all workers, or relevant staff haven’t been trained on it. In other words, the policy may reflect good intentions but isn’t fully adopted across the organization.

Interpretation and Expected Best Practices: The SMETA 7 interpretation guidance explains that this statement must cover a commitment to all human rights without exception and have formal top management approval. It can take various forms: some companies explicitly adopt the ETI (Ethical Trading Initiative) Base Code or other international standards as a reference, while others draft their own ethical statement. The key is that the content reflects labor human rights principles (no forced labor, no discrimination, freedom of association, living wage, etc., which align with SMETA’s other chapters). It must be a public company commitment, not a confidential document.

Communicating it to all workers is essential: this can be done through general training, onboarding for new hires, distributing copies, posting on notice boards or intranet, etc. Every employee should at least generally know that the company has a policy respecting workplace human rights.

Additionally, the policy must be provided as specific training for “relevant” staff. Who are relevant? Those with critical roles in implementing these standards, e.g., human resources teams, production supervisors (who directly manage workers’ conditions), compliance or CSR staff, area managers, etc. These individuals need deeper knowledge of the policy to apply it practically and make aligned decisions.

If the company has no policy in this area, the auditor will raise the finding “No written human rights policy or inadequate.” If there is a policy but it fails any requirement (lacking top approval, dissemination, or training), the finding will be “Human rights policy exists but does not fully meet the requirement…,” specifying the missing components. Though seemingly administrative, this sub-requirement is significant because it shows the company’s structural commitment to ethics: having or not having a policy speaks volumes about management’s approach.

Practical Examples:

Manufacturing: An electronics manufacturing company has a code of conduct mentioning general values, but during a SMETA 7 audit, it’s found that: (a) The document lacks a signature or approval from top management, drafted by HR without explicit board endorsement; (b) Most operators have never heard of the code; (c) Supervisors haven’t been trained on applying human rights issues (e.g., they don’t know how to handle child labor or harassment cases because they were never trained). In this case, although a document exists, it doesn’t comply with 0.D. It lacks top-level approval and dissemination/training. The auditor will likely note it as “human rights policy exists but does not fully meet the requirement,” recommending addressing these gaps.
Services: Imagine a consulting or call center company. If it has no declared human rights or labor standards policy, it would fail 0.D by not formally demonstrating commitment. Another example: the company has a robust policy signed by the CEO, committing to non-discrimination, decent work, etc.; however, it’s only on the corporate website in English. Local Spanish-speaking employees have never read it or been trained on it. During interviews, workers are unaware of the document’s existence. This shows it wasn’t communicated to all staff, so despite existing on paper, it’s not truly implemented. It would also be a 0.D breach due to lack of communication and training.

Common Mistakes:

Assuming a generic code suffices: Sometimes, companies have a general ethics code but not specific to labor rights, or one covering only industrial safety but not aspects like freedom of association or non-exploitation. Assuming any code “is enough” is a mistake. The policy must explicitly address labor human rights.
Not involving top management: Drafting a policy at a mid-level (by a department) without formal top management approval. This diminishes the document’s authority and priority. A sign of this is a policy lacking the General Director’s signature or evidence that top management knows and supports it.
Lack of internal dissemination: Publishing the policy on the web or in a manual but not ensuring employees understand it. If it’s not translated into the local language or distributed but never explained, the message doesn’t sink in. It’s common for operational-level workers to be unaware because no one communicated it practically.
Not training critical staff: Assuming handing out the document is enough. Without specific training sessions, e.g., for HR or supervisors, they may not know how to address real ethical dilemmas. A mistake would be not training the recruitment team on the commitment to no forced labor or managers on respecting union freedom.
Outdated or boilerplate policy: Having a policy created years ago that’s never reviewed or integrated into daily operations. Such a document may be outdated relative to new laws or standards (e.g., today’s focus on supply chain due diligence). If the audit shows the policy is old and unknown, it will reflect a lack of seriousness in implementation.

Recommendations for Proper Compliance with 0.D:

Develop or Update the Human Rights Policy: If none exists, create a Human Rights Policy aligned with recognized standards (e.g., ETI Base Code, UN Principles) covering all relevant labor topics. Keep it concise, clear, and accessible. Include commitments to each labor right (no child labor, no forced labor, non-discrimination, freedom of association, safe conditions, decent hours, fair pay, etc.).
Top-Level Approval: Ensure the policy is reviewed and approved by top management. Ideally, have the CEO or General Director’s signature on the document or a board resolution adopting it. This sends a strong commitment message. Invite management to participate in its launch or official communication within the company.
Communicate to All Staff: Widely share the policy. For example, provide it during onboarding for new hires; run internal campaigns (posters in common areas highlighting key commitments); send corporate emails; upload it to the intranet prominently. Ensure versions are in the language your workers understand (for low-literacy staff, complement with talks or simple visual materials). Everyone should know the company’s values and rules for fair, ethical treatment.
Targeted Training: Identify roles needing deeper understanding. For example, HR should receive detailed training on ethical hiring, non-discrimination, and handling harassment complaints. Operations managers and supervisors should be trained on respecting rights in daily practice (e.g., managing voluntary overtime, promoting safety, reporting incidents). Offer periodic workshops or short courses (at least annually) on the policy and practical cases. Document attendance, as the auditor may request evidence.
Integrate into Daily Management: Don’t let the policy be a dead letter. Embed its principles in company procedures. For example, if it states “we respect freedom of association,” ensure the internal regulations don’t contradict it and that supervisors know workers can unionize. If it says “safety first,” back it with investments in PPE and safety committees. Show coherence between the policy’s declarations and the company’s actions.
Periodic Review: Establish a review (e.g., every two years) to update the policy based on regulatory or standard changes. Involve top management again and incorporate employee or representative feedback if possible. Keeping it current and relevant prevents obsolescence.

Complying with 0.D shows the company doesn’t just react to the audit but has a high-level commitment to ethical values. A SMETA auditor will verify the policy’s existence, content, and application. If everyone in the organization knows and practices the policy’s principles, it not only meets this requirement but fosters a more respectful, standards-aligned workplace culture.

Conclusion

Requirement 0 of SMETA 7, “Enabling an Accurate Assessment,” lays the foundation for a successful ethical audit. It encompasses fundamental aspects of transparency, honesty, and integrity from the audited site: from not obstructing the auditor’s work or hiding information, to refraining from any form of bribery, ensuring accurate site information, and maintaining a formal commitment to human rights. If a company fully complies with these sub-requirements (0.A, 0.B, 0.C, 0.D), it creates the ideal environment for the audit to proceed smoothly and truthfully, benefiting both parties. The auditor can verify on-site compliance with confidence, and the company receives a fair evaluation of its practices.

To prepare adequately for a SMETA audit, organizations should start with Requirement 0. This involves an honest self-assessment: Are we facilitating or hindering the audit? Are our data and documents reliable? Does our staff understand our ethical commitments? By internally reinforcing a culture of openness and compliance—e.g., training staff, reviewing documentation, updating Sedex profiles, and reaffirming policies from top management—a solid foundation is built that not only meets SMETA but improves daily management. Ultimately, complying with Requirement 0 isn’t just about “passing” an audit but fostering trust: trust between the company and auditors, and between the company and its clients, workers, and other stakeholders.

In conclusion, “Enabling an Accurate Assessment” is more than a checklist: it’s adopting a proactive stance of collaboration, transparency, and ethical commitment. A company that fully embraces these principles will not only be ready for any SMETA audit but will demonstrate leadership in social compliance. Preparing in advance, educating the organization, and taking these guidelines seriously ensures that when the auditor arrives, there are no unpleasant surprises, but a clear process reflecting the reality—both the good and the improvable—of the company. Complying with Requirement 0 is the first step to a successful outcome in any SMETA ethical audit, setting the stage for advancing other standards with credibility and success.

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This is the first chapter of the SMETA 7 Course, covering Requirement 0. If you’d like to see the remaining chapters translated into English, please leave a comment below! I’d be delighted to share more based on your interest. Thank you for reading, and I look forward to your feedback!

Introduction

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0.A: Unobstructed Audit with Authentic Records

0.B: Prohibition of Bribery or Coercion of the Auditor

0.C: Accurate Site Description and Truthful Sedex Profile

0.D: Written, Approved, and Communicated Human Rights Policy

Conclusion

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Publicado por DENIS TOLEDO

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