Q: We hear that WRAP is an industry-controlled program.
A: WRAP is an independent, international non-profit organization with an independent board of directors. By charter, the majority of WRAP¡¯s board is ¡°non-industry¡± and a simple majority vote of the board can change any part of WRAP¡¯s codes, policies and/or procedures at any time. The Chairman of the Board is required to be a non-industry representative. Hence, it is not possible for ¡°industry¡± to ¡°control¡± WRAP.

In addition, three non-governmental organizations and two universities are represented on the WRAP Board.

Q: WRAP was started by the apparel industry. How can it be independent?
A: The American Apparel & Footwear Association (AAFA) spent US$1,300,000 of its money to fund a three-year study in the late 1990¡¯s to fully examine working conditions in sewn products factories around the world. Those funds were an investment by the industry as a demonstration of its commitment to create a program which now certifies legal, ethical and humane working conditions in factories around the world.

While the AAFA continues to support the work of WRAP, there is no legal or other connection between the AAFA and WRAP. And, we are very grateful for the support of the International Apparel Federation and its 34 member associations, and the 22 other international apparel associations for their support.

Q: How does a company become a member of WRAP?
A: WRAP is not a membership organization. WRAP is a standard-setting, training and certification body which receives its income from registration, training and accreditation fees. It does not seek nor accept government grants or funding thus allowing for full financial independence.

Q: Aren't WRAP standards a disguise for non-tariff barriers to trade?
A: The first WRAP principle is compliance with local law. WRAP fully recognizes and respects the sovereignty of each nation and the fact that virtually all countries where WRAP operates are full members of the United Nations. When certifying factories, WRAP first looks to local law, then generally-accepted international labor practices which mirror relevant International Labor Organization conventions ¨C adopted by most countries around the world.

Q: Why doesn't WRAP have a maximum working hour provision?
A: Again, WRAP respects local law. We respect the right of local governments to determine the working hour law for their own citizens.

Q: WRAP requires factory give their employee freedom to choose whether or not to belong to a union. But aren't worker unions necessary to ensure social compliance in a factory?
A: WRAP believes that the workers within a factory should choose whether or not to be represented by a third-party organization of their choice abiding by the laws of their country. All countries have laws which govern the election of employee representation groups which WRAP fully respects. If workers decide to represent themselves, or have a union as their representative, is the choice of the workers.

Q: I read that WRAP's principles on minimum age do not correspond to the relevant ILO conventions.
A: Every country establishes their own laws for minimum ages of employment and restrictions on ¡°dangerous work¡± for younger workers. WRAP¡¯s policy is for a minimum age of 14, or the minimum age of employment by law, or the minimum age for schooling, whichever is greater.

Further, ILO conventions provide for workers to the age of 12 in certain circumstances, an age which WRAP believes to be too low for factory work.

Q: WRAP is located next to Washington, DC in Arlington, Virginia. I understand WRAP strongly relies upon the US government for support.
A: WRAP is not affiliated with the US government nor any other government in any way. WRAP accepts no grants or funding from any government, it is non-partisan and apolitical, and does not lobby for any cause or legislation.

Q: How does WRAP claim to have developed a "Universal Code of Ethical Conduct" (UCEC)?
A: The WRAP principles are applicable to any labor-intensive manufacturing environment. Child labor is child labor whether in a sewing factory, a tuna cannery, a jewelry factory or a meat processing facility. Health and safety concerns and proper protective equipment is applicable in a furniture factory or a chemicals facility. Thus, the principles of the UCEC apply to all labor-intensive facilities.

Q: Why was the UCEC developed? Isn't this outside the expertise of an apparel certification body?
A: Brands and retailers that relied upon WRAP to audit and certify their sewn products plants requested WRAP to use the knowledge and expertise of its staff to extend the code to other industries when they began licensing their brands to other products. Thus, the UCEC, modified for the applicable manufacturing environment, apply to all such facilities.

Q: Isn't WRAP just a "check list" approach to compliance on the day the audit is conducted?
A: WRAP takes a ¡°management systems¡± approach toward compliance. Thus, each facility is required to assign specific personnel to each principle, conduct training for the workers on the requirements of WRAP and communicate the WRAP principles, in writing and in the local language, conduct its own audits to ensure on-going compliance, and have a mechanism to fix problems found during those internal audits. Thus, when audits by WRAP are conducted ¨C all on an unannounced basis ¨C WRAP seeks to verify that the proper systems, written policies and procedures, and internal controls are in place for the facility to maintain ongoing compliance.

Q: We heard that factories are only audited once per year.
A: If a factory demonstrates full compliance with the WRAP principles during the audit, it is certified for one year. However, unannounced follow-up audits are conducted on a selected number of factories based on a risk profile to ensure they maintain compliance. If they are found not to be in compliance, they either receive a written corrective action plan or they are decertified based on the severity of the violations.

Q: Does WRAP certify factories that aren't paying the workers the legal wages and benefits?
A: No. WRAP requires that all wages and benefits due employees to be paid in full and on time.

Q: What if workers are working beyond the legal limits of a country?
A: WRAP requires that all overtime work be voluntary and fully paid, including any required overtime premium. If a factory is working in excess of the allowed hours, a corrective action plan must be put in place to reduce the hours to the legal limit, unless the factory has a legal waiver issued by the relevant government agency.

Q: Why doesn't WRAP address the "living wage"?
A: The discussion and debate about a ¡°living wage¡± has been going on for centuries. Numerous recent attempts to define such a wage have been made but no consensus or agreement has been reached on such a definition. WRAP continues to follow the issue and is supportive of the concept, but until a clear and agreed-upon definition is put forth, WRAP cannot certify that which cannot be defined.

Q: Why doesn't WRAP adopt all ILO conventions as minimum requirements?
A: As stated earlier, WRAP first and foremost looks to the laws of a country in which a factory is located. WRAP believes in the sovereign rights of each country. ILO conventions are not law but conventions passed by a tripartite body of the United Nations and only become law in a country when that country ratifies the convention. A listing of relevant conventions, and which countries have passed those conventions, can be found on the following ILO website: http://www.ilo.org/ilolex/english/docs/declworld.htm.

Q: Why doesn't WRAP publish a list of the brands and retailers that accept WRAP certification?
A: The decision to accept a WRAP certification as sufficient to meet the compliance needs of a brand or retailer solely rest with that organization. Some companies prefer not to discuss their compliance programs while others are quite public and even prepare annual CSR reports. Thus, to respect the policies of all companies, WRAP defers to those companies to make their own choice about publicly acknowledging WRAP participation.

Q: WRAP doesn't have labor organizations represented on its board of directors. Why not?
A: WRAP has reached out to several labor organizations over the years and has, in fact, had strong representation from trade union representatives. The first chair of the board was a former Vice President of the AFL-CIO. WRAP continues to reach out to all interested parties for consultation and dialogue including the academic community, relevant NGOs and trade union representatives.

Q: Why doesn't WRAP issue an annual report?
A: The preparation of annual reports is extremely time-consuming and expensive. As WRAP has a small staff and limited resources, such a report simply has not been possible in the past. However, preparations are under way for such a report next year in anticipation of WRAP¡¯s ten-year anniversary.

Q: How does WRAP handle complaints from workers in a factory about abuses from management or unhealthy working conditions?
A: All complaints and reports, from workers or other groups, are taken seriously and are immediately and fully investigated. If the situation warrants, a WRAP employee will personally visit the factory, interview all relevant parties and review all pertinent records to determine the veracity of the complaint. Management of the factories understands, in advance, the right of WRAP to conduct such investigations and it is part of the certification requirements.

Q: What is WRAP doing to work with other organizations, such as BSCI, SAI, ETI and others, to work toward one universally accepted code of practice?
A: WRAP stands ready to work with any and all relevant organizations on the issue of convergence and mutual recognition. Some meetings have been held over the years and some progress has been made.

Q: What has WRAP done to ensure the auditors that actually inspect the factories are competent to do so?
A: The WRAP audit process was initially developed over a three-year period during which hundreds of hours of consultations were held with subject matter experts, technical experts, human rights advocates, academics, NGOs, labor leaders and more to ensure the rigor of the WRAP process. Those consultations continue to ensure the WRAP program remains relevant, timely and rigorous.

WRAP has translated that experience to an equally rigorous set of qualifications and requirements for WRAP auditors. A comprehensive training program was developed, the best social systems trainer in the world was hired, and our training program was submitted to the International Register of Certificated Auditors for review and accreditation. Every new WRAP auditor is required to attend our three-day training program, pass a written examination and attend refresher training every two years. Continuing desk reviews of each auditor¡¯s work is completed to ensure ongoing competence. Auditors who fail to meet our requirements are either required to attend further training or are removed from the approved list.

Q: Are representatives of trade unions or NGOs allowed to become WRAP auditors?
A: Yes. Any person, sponsored by a legitimate organization that demonstrates competence in the required areas and has the qualifications to become a WRAP auditor is admitted to our training programs.