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5. Higg FEM Approval Maintenance and Verifier List

Policy Title:         Higg FEM Approval Maintenance and Verifier List

Policy Number:   VPM - 004

Issue Date:         February 16, 2018

Authorization:    SAC Vice President - Higg Index

Distribution:       Internal – All

                           External – All potential and current Eligible FEM Verifiers

 

Table of Contents

1     General Information

2     Status Duration and Maintenance

3     Approved Verifier List

4     Conditions for Removal

  4.1      Verifier Quality Scorecard

  4.2      General Expectations

  4.3      Improper Verifications

  4.4      Timeliness

5     Verification Companies

6     Ethics

  6.1      Ethics – General Information

  6.2      Ethical Investigations – Individuals

  6.3      Ethical Investigations – Verification Firms

7     Conflict of Interest

  

1     General Information

The SAC has a vetting process that is designed to have only the most qualified Verifiers in the industry conducting Higg FEM Verifications.  It is the hope of the SAC, Higg Users, and the audience for Higg scores and data that each Verification be done correctly, accurately, on-time and honestly.   SAC reserves the right to score verifiers based on a variety of parameters to ensure the organization and programmatic expectations are being met. 

If there are instances where Verifiers do not follow the process, make mistakes, or act in a way that goes against SAC's requirements, SAC may, at its discretion, and remove Verifier’s names from the FEM Higg Verifier List. 

2     Status Duration and Maintenance

  • Duration of Eligibility is for the for one year from the time the Verifier passed their Eligibility Exam
  • Extensions to the eligibility duration:
    • Verifiers will be allowed to verify up to one month after their one-year expiration date
    • Prior to the end of this additional month the verifier must be go through the process to become eligible prior to conducting verifications
  1. At the end of the one-year time frame, Verifiers:
    • Are no longer allowed to use the term ‘FEM Higg Verifier’
    • May not market or use their certificate as an SAC FEM Higg Verifier in getting new verification business
    • Will be removed from the SAC FEM Higg Verifier list, unless they are re-approved.
  2. Verifiers can become reapproved for another year by:
    • Applying for the next year’s approval, including submitting all required supporting materials
    • Completing any required training
    • Passing an exam, if required

3     Approved Verifier List

  1. When an individual becomes eligible through the application process, completes the required training, and passes the associated exam(s), their name will be added to the ‘FEM Higg Verifier List’
  2. The FEM Higg Verifier List is hosted on the Sumerra website: https://slemma.com/share/SACApprovedVerifiersTrainersList
  3. The FEM Higg Verifier List is available for member companies and others to see
  4. Information on the list includes:
    • Name of the Verifier
    • Name of their company/organization
    • Contact information for this individual
    • Contact information for their company
    • SAC unique Verifier Number
    • Type of Verifier
      • Generalist Verifier
      • Chemical Specialist Verifier
    • Language capability
  5. The VPM Manages the list, updating the list as needed to keep as up-to-date as possible
  6. If changes are required to this list, contact the VPM; changes may include:
    • Removal of names from the list at the company’s discretion (i.e. Verifies are no longer employed by the company)
    • Changes to contact information
  7. Verifiers can be removed from this list, and their eligibility revoked, through processes and or issues described within this document

 

4     Conditions for Removal

  4.1    Verifier Quality Scorecard

  1. Eligible verifiers are measured on quality metrics which is used to create a ‘Verifier Scorecard’; the scorecard includes:
    • Quality – how well the Verifier measured the factory during the Verifications they completed, including:
      • Proper scoring application
      • Proper interpretation of Higg guidance
      • Proper environmental knowledge
    • Professionalism:
      • How well the Verifier followed the protocols
      • Interactions with the Facility, SAC, VPM
    • Timeliness – following timeliness requirements
  2. Information that informs the scorecard comes from:
    • Quality Reviews
    • Member Companies and/or Facilities
    • Surveys received after Verifications are completed
    • Shadow or Follow-up Verifications and Assessments
    • Investigations
  3. This scorecard may be used:
    • For removal from the FEM Higg Verifier List
    • By Member Companies and/or Facilities as they select Verifiers to conduct Verifications
    • To require or suggest additional training needs by the Verifier(s)
  4. The scores and the scorecards are created and managed by the VPM

 

  4.2    General Expectations

  1. Verifiers must follow SAC protocols when conducting Verifications; this includes, but is not limited to:
    • Acting in an ethical and professional manner
    • Ensuring the Verification follows the right scope – i.e. defining factory location(s), time period to be verified, etc.
    • Spending the proper time at the facility
    • Interviewing the correct people – the right number and those with the right knowledge and information
    • Using and completing the correct forms (including the correct versions), guidance documents, and other correct information sources
    • Providing correct and accurate data and information, including making proper judgements, when required
    • Correctly uploading the forms into the correct locations
    • Meeting all timelines
    • Protecting information collected during all verifications, including:
      • Not leaving their belongings (such as notes or other verification related documents) out in the open for public consumption
      • Verifiers shall ask permission from facility staff when accessing information related to verification topics.
      • Verifiers will ensure any electronic devices are secured with a password to prevent access to verification information.
      • Verifiers shall not discuss the, verification results, or any other information gained from the verification with anyone outside of the facility management staff, the verification team or the VPM
    • Communicate in a timely manner with the VPM regarding any questions or investigations conducted by the VMP, including but not limited to:
      • Ethical Investigations
      • Quality Reviews
      • Shadow or Follow-up Assessments
  1. Verifiers are responsible to ensure they are using the most up to date information; this information can be found on:
  2. If a Verifier is found to not be meeting these expectations, the VPM may decide to suspend or remove the Verifier from the Eligible FEM Higg Verifier list permanently or until appropriate corrective actions (determined by the VPM), can be made.

  4.3    Improper Verifications

  1. If Verifications were done improperly, the Verifier is expected to:
    • Correct the Verification for no additional charge
    • Learn from the experience so that future verifications do not repeat similar issues 
  1. If/when the VPM discovers an improper verification:
    • The VPM will provide guidance (training) on the issue so that the Verifier can correct the information
    • The VPM includes this information on the Verifier Quality Scorecard
  2. If the VPM finds continued improper verifications completed after additional guidance and training has been conducted:
    • The VPM may choose to allow the Verifier to stay on the FEM Higg Verifier list, provided:
      • Additional training, specified by the VPM, is successfully completed
      • The Verifier agrees to a probationary period where their verifications may be observed at a heightened level (e.g. through shadow, peer, or desktop reviews) to evaluate their ability to follow the correct, established processes
    • The VPM includes this information on the Verifier Quality Scorecard
    • The VPM may choose to revoke eligibility to conduct FEM Higg Verifications and remove the Verifier from the FEM Higg Verifier List
      • If the Verifier wants to become reapproved:
        • They must go through the approval process again, which includes reapplying and retaking the training and exam
        • If reapproved, they start with the same QA score as when they leave (thereby ensuring Verifiers with low scores not entering the system as a ‘new’ verifier with higher scores)

  4.4    Timeliness

  1. Onsite and Offsite Verification Results are due within 5 business days of completing the Verification process
  2. All Verification results are to be uploaded to the Higg.org platform
  3. If a verification result is submitted late:
    • The Verifier score is impacted for that Verification, as per the Quality Assurance Process and Scorecard
    • The verification results are expected to be uploaded as quickly as possible after the due date
    • If the verification results are more than 5 business days late, at the request of the Facility,
      • The SAC or the VPM may get involved in trying to determine what the cause of the delay is
      • The SAC or the VPM may get involved if there is anything that can be done to speed report submission
  1. If a Verifier is systematically late, as defined by the VPM (typically this is late on more than 25% of the submissions):
    • A warning will be provided to the Verifier, indicating:
      • That if Verifications are not submitted on time that the Verifier's approval and listing on the Approved Verifier list may be revoked
      • The time period by which on-time submittals are expected
      • Any other pertinent information
    • If the warning is given and expectations are not met, as indicted in the warning letter, the VPM may choose to:
      • Revoke eligibility, including removal of the Verifier from the FEM Higg Verifier List
      • If the verifier has shown significant improvement but did not fully meet expectations, they may receive another warning, indicating:
        • That if Verifications are not submitted on time that eligibility may be revoked
        • The time period by which on-time submittals are expected
        • Any other pertinent information

5     Verification Companies

  1. Verification Companies are not ‘approved’ by the SAC or by the VPM, rather, individual Verifiers are included on the Eligible Higg FEM Verifier list; therefore, any company who has eligible verifiers may have Verifiers apply and become eligible to conduct Higg FEM Verifications
  2. Verification Companies may, however, be restricted or prohibited from having Verifiers conduct Higg FEM Verifications
    • Verification Company restrictions
      • Are at the sole decision of the VPM, with the paramount determining factor being the integrity of the Higg FEM Verification Program
      • Length of ban:
        • May have a set period of time in which the restrictions will be lifted
        • May have no end date
      • Are instituted when:
        • A Verification Company has a member of the Upper Management Staff that is found to be unethical, and it is believed that this act may impact the integrity of the SAC Higg FEM Verification Program
        • A Verification Company is found to have an unethical culture, or a culture that supports unethical behaviors of Verifiers
        • A Verification Company is found to have processes or procedures that encourage or incentivize unethical behaviors
        • A Verification Company does not have proper training, policies, procedures or other similar safeguards in place to encourage or enforce ethical behaviors amongst their Verification Staff
        • The VPM believes that, for any reason, the integrity of the Higg FEM Verification Program may be impacted by the Verification Company being represented in the program

6     Ethics

  6.1    Ethics – General Information

  1. Ethical behaviors and perceptions are paramount to the Higg FEM Verification Program
    • Any unethical behavior or perceptions is unacceptable
    • The VPM’s main duty is to protect the integrity of the Higg FEM Verification Program; therefore, in all ethical investigations or decisions, they will lean towards protecting the integrity of Higg FEM Verification Program
  2. VPM has sole authority to:
    • Conduct ethical investigations
    • Determine and enforce any consequences, including revoking Verifier eligibility
  3. Ethical investigations include discussions with any individuals, whether at the manufacturer, verification company, SAC (including VEP) or others that can provide information pertinent to the investigation
  4. Verifiers and Verification Firms acknowledge:
    • That the integrity of the Higg FEM Verification Program is paramount
    • That the ability to conduct Higg FEM Verifications is a privilege, and not a right
    • That they may be removed from the Eligible Higg FEM Verifier List at any time

  6.2    Ethical Investigations – Individuals:

  1. Verifier Expectations:
    • Verifiers must never act unethically, or give the perception of unethical behavior(s)
    • The integrity of the SAC and Higg FEM Verification program is paramount, and it is expected that Verifiers work in a manner that enhances this integrity
  2. The VPM has sole authority to:
    • Investigate ethical issues
    • Determine results from ethical investigations
    • Apply disciplinary actions, if needed
  3. If there is a ‘Credible Report’ or suspicion of unethical behaviors by a Verifier:
    • The Verifier is immediately removed from the FEM Higg Verifier List
    • The Verifier is not permitted to conduct Higg-related work until the investigation is complete or until permitted by the VPM
    • NOTE: ‘Credible Report’ includes:
      • Information received by the VPM that details of an alleged incident (or incidents) including:
        • Verifier or Verification Company Name
        • Place (Facility)
        • Date or time
        • Alleged ethical violation(s)
      • Information submitted by any of the following:
        • SAC Member Companies
        • Facilities
        • Organizations
        • Verifying Bodies
        • NGO’s
        • Other knowledgeable individuals
      • If information is received in the report that is not ‘credible’, the VPM will attempt to validate the information; until the information is validated, the report is considered ‘not credible’ and no actions are taken to revoke eligibility or to suspend the Verifier
      • The VPM will investigate the incident; this may include:
        • Talking with or getting information from:
          • The Verifier
          • The Verification Company
          • The Facility (or Facilities) where the alleged incident(s) occurred
          • Other facilities where this Verifier conducted work
          • Other knowledgeable individuals or companies
        • Investigating the Verifier’s activities and work outside of the FEM Higg Verification Program
  1. Investigation Results:
    • If the investigation results show no unethical actions or behaviors and there is no suspected unethical actions or behaviors, the Verifier is reinstated by the VPM and they may conduct Higg-related work, including verification activities
    • If the investigation cannot confirm unethical activities or behaviors, but there are suspected unethical activities or behaviors, the VPM may:
      • Suspend the Verifier for a period of time not to exceed 18 months
      • Provide a warning to the Verifier
      • Place the Verifier on probation for up to 2 years, which may include the following stipulations (at the digression of the VPM):
        • Providing a warning to the Verification Company
        • Require the Verification Company to provide additional training to the Verifier
        • Require the Verification Company to provide additional oversight to/for the Verifier
        • Conduct additional Quality Oversight on the Verifier
        • Other activities or tasks that will protect the integrity, and perception of integrity, of the SAC and Higg Program as defined by the VPM
      • If the investigation confirms unethical activities or behaviors:
        • The Verifier is removed from the Eligible Higg FEM Verifier List
        • The Verifier is suspended from conducting all Higg related work
          • The length of the suspension
            • Is generally forever
            • May have an end duration, but at no time may be less than 12 months

  6.3    Ethical Investigations – Verification Firms

  1. Verification Firm Expectations:
    • Verification Firms must never act unethically, or give the perception of unethical behavior).
    • The integrity of the SAC and Higg FEM Verification program is paramount, and it is expected that Verification Firms work in a manner that enhances this integrity
  2. The VPM has sole authority to:
    • Investigate ethical issues
    • Determine results from ethical investigations
    • Apply disciplinary actions, if needed
  3. If there is a ‘Credible Report’ or suspicion of unethical behaviors by a Verification Company:
    • Some (or all) Verifiers from that Verification Company may be removed from the Eligible Higg FEM Verifier List
    • The Verifiers are not permitted to conduct Higg-related work until the investigation is complete, or until permitted by the VPM
    • NOTE: ‘Credible Report’ includes:
      • Information received that includes some details, including:
        • Verifier or Verification Company Name
        • Place (Facility)
        • Date or time
        • Alleged ethical violation(s)
      • Information submitted by any of the following:
        • SAC Member Companies
        • Facilities
        • Organizations
        • Verifying Bodies
        • NGO’s
        • Other knowledgeable individuals
      • ‘Verification Company’ includes:
        • Multiple Verifiers from the same company that may be working together in an unethical manner
        • Systemic ethical issues (i.e. many Verifiers working for one company working unethically)
        • Upper Management from a company that is operating in an unethical behavior
        • Company processes, systems, procedures or other systemic measures that encourage, force, or incentivize individual Verifiers to work in an unethical manner
        • Companies that hide or are not transparent with the VPM during ethical investigations of their Verifiers
        • NOTE: ‘Verification Company’ is not an Individual Verifier operating independently in an unethical manner
      • If information is received that is not ‘credible’, the VPM will attempt to validate the information; until the information is validated, the report is considered ‘not credible’ and no actions are taken to revoke approval or to suspend the company or its Verifiers
      • The VPM will investigate the company; this may include:
        • Talking with or getting information from:
          • Verifiers
          • The Verification Company
          • The Facility (or Facilities) where the alleged incident(s) occurred
          • Other facilities where this Verifier conducted work
          • Other knowledgeable individuals or companies
  1. Investigation Results:
    • If the investigation results show no unethical actions or behaviors and there is no suspected unethical actions or behaviors, the Verification Company is reinstated and they may conduct Higg-related work, including verification activities
    • If the investigation cannot confirm unethical activities or behaviors, but there are suspected unethical activities or behaviors, the VPM may:
      • Suspend the Verification Company for a period of time not to exceed 18 months
      • Provide a warning to the Verification Company
      • Place the Verification Company on probation for up to 2 years, which may include the following stipulations (at the digression of the VPM):
        • Providing a warning to the Verification Company
        • Require the Verification Company to provide additional training to their Verifiers
        • Require the Verification Company to provide additional oversight to/for the Verifiers
        • Conduct additional Quality Oversight on the Verifiers
        • Other activities or tasks that will protect the integrity, and perception of integrity, of the SAC and Higg Program as defined by the VPM
      • If the investigation confirms unethical activities or behaviors:
        • The Verification Company’s Verifiers are removed from the Approved FEM Verifier List
        • The Verification Company is suspended and prohibited from conducting all Higg related work
          • The length of the suspension
            • Is generally forever
            • May have an end duration, but at no time may be shorter than 12 months

7     Conflict of Interest

  1. Verifications used for consumer-facing communications must be conducted by a verifier that has no business relationship or influence with the factory he/she is verifying.
  2. A strict Code of Conduct and the Higg Terms of Use governs this work to ensure uninfluenced and credible results are communicated.
    • There is a conflict if Trainers or Consultants are Verifiers; specifically:
      • Verifiers cannot perform a Verification if they provided training or consulting to that facility
      • An exception is if the training was done in a ‘large group setting’ in which the trainer was speaking to a large audience about general topics and did not have specific discussions with or specifically assist any individual facility
    • In order to remove bias and potential conflict of interest, a verifier will not assess a facility twice unless given written permission by SAC or the VPM
    • At no time should verifiers engage in selling other services their organization offers during the Verification process
    • Where there is a Buyer-Suppliers relationship of the Verifier, verified scores cannot be communicated by the supplier or brand public ally per Higg Index Terms of Use. Examples include:
      • Brand-Supplier
      • Manufacturer-Vendor/Supplier
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