Together for Sustainability
The Chemical Industry Initiative for
Sustainable Supply Chains

Third Party Audit Program
Version 4.0

One Audit for All

Table of contents
About this document............................................................................................................... - 2 Introduction: Together for Sustainability (TfS)......................................................................... - 2 Introduction: TfS Audit Program ............................................................................................. - 2 Documents and References ................................................................................................... - 3 1

Audit Objectives, Scope and Duration ......................................................................... - 5 1.1

Audit Objective ......................................................................................................... - 5 -1.2

Audit Scope.............................................................................................................. - 6 -1.3

Multi-site audit .......................................................................................................... - 7 -1.4

Audit Duration & Lead-time ...................................................................................... - 7 -1.5

Audit Cost ................................................................................................................ - 8 -1.6

Combined Audits ...................................................................................................... - 9 -1.7

Recognition of other audit standards ........................................................................ - 9 -2

Auditor Approval and Selection ................................................................................... - 9 2.1

Selection of Audit Companies .................................................................................. - 9 -2.2

Approval Process for Auditors ................................................................................ - 10 -2.3

Approval Criteria for Auditors ................................................................................. - 10 -2.4

Witness Audits ....................................................................................................... - 11 -Annex 1: Glossary ................................................................................................................ - 11 Annex 2: Equivalent auditing standards................................................................................ - 14 Annex 3: Short Audits........................................................................................................... - 14 Annex 4: Enhanced Audits ................................................................................................... - 14 A4.1 Annex 4 – Enhanced TfS (eTfS) Audit ............................................................................. 18

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Introduction: Together for Sustainability (TfS)

About this document
This document has been developed by the Together for Sustainability (TfS) Initiative as an
information source for TfS members, suppliers, audit companies, auditors, potential new
members, and other interested stakeholders.
It sets out the objectives, requirements and procedures of the TfS Audit Program to ensure acredible, transparent, and consistent audit approach.

Introduction: Together for Sustainability (TfS)
TfS is an international non-profit association under Belgian law (“association internationale sansbut lucratif – AISBL”). Founded in August 2011 by the Chief Procurement Officers of six
multinational companies, TfS has developed and implemented a global audit and assessment
program to assess and improve sustainability practices within the supply chains of the Chemical
Industry. In 2015 the TfS Office opened in the CEFIC premises in Brussels.

Introduction: TfS Audit Program
The TfS Audit Program is one element of the overall TfS framework to support supply chain
partners (namely buyers and suppliers) in their continuous efforts to improve sustainability in theirbusiness practices.
A TfS audit is an on-site examination by an independent third party auditor looking at relevant
sustainability practices. It typically covers a single or combined business location such as a
production site or a warehouse. Following the TfS audit process the supplier's sustainability
performance is verified against a pre-defined set of audit criteria covering management,
environment, health & safety, labor & human rights, and governance issues. These topics havebeen defined by TfS and are tailored to the requirements of the Chemical Industry.
TfS audits are performed by a pool of approved sustainability auditors from independent audit
companies. Audits can neither be passed nor failed, but highlight areas of improvement that are
documented in audit reports.
Following the completion of a Data Sharing Agreement (DSA) by the auditee, audit reports areshared between the supplier and all TfS member companies, enabling members and suppliers tohave a productive dialogue on where improvements can be made. The supplier owns the audit
report and is free to share it with any current or future customers, beyond the TfS members.
The following external references have been used to develop the TfS Audit Questionnaire,
amongst others:• United Nations Global Compact (UNGC)• Safety & Quality Assessment System (SQAS of the European Chemical Industry Council(CEFIC)• Responsible Care Global Charter of the ICCA
• International Labor Organization (ILO)
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•
•
•

•
•
•
•
•

Declaration on Fundamental Principles and Rights at Work as well as other key ILO
statements.
Conventions on Labor Standards
International Organization for Standardization (ISO)o ISO 26000: Guidance on Social Responsibilityo ISO 9001: Standard for Quality Management Systems
o ISO 14001: Standard for Environmental Management Systems
o ISO 19011: Guidelines for Quality and/or Environmental Management System
Auditing
OHSAS 18001: Occupational Health and Safety Assessment Series
Social Accountability International, SA8000 Standard
United Nations, Universal Declaration of Human Rights
United Nations, UN Convention against Corruption
Organization for Economic Co-operation and Development, OECD Guidelines forMultinational Enterprises

Documents and References
All documents related to the TfS audit process are listed below. TfS documents bear version
numbers and are approved by the TfS Work Stream before issuance.
Document Type

Document Name

Description

TfS One-pager

An introduction to the purpose, objectives
and structure of the TfS initiative.

Frequently Asked
Questions (FAQ)

Further detail on the TfS organization,
audit and assessment programs in a“question and answer format”.

TfS Supplier Academy

E-Learning modules available on the TfS
website, providing a background on
sustainability and describing the audit
process.

Auditor Approval

Auditor Evaluation Form

A form used by the TfS Office to evaluate
the credentials of auditors nominated to
conduct TfS audits.

Audit Program

Third Party Audit Program
4.0 (This document)

The reference document for the TfS Audit
Program, describing the process, roles
and responsibilities of all involved indetail.

Background

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Online audit preparation

Online form editable by suppliers andaccessible for members. This form
replaces the previous Supplicer
Confirmation Form (SFC) and audit
request form.
The supplier uses this to send an
automared audit request to all 4 audit
companies. It is also used as an
information tool for the buyers.

Preparation for an
Audit

During an Audit

Data Sharing Agreement(DSA)

A legal document signed by the supplier
to confirm consent for the audit to beshared with TfS members.

Supplier Academy: Audit
Process

Online training modules for suppliers tounderstand the basics of sustainability
and the TfS audit process.

Audit Preparation
Document

A checklist for suppliers, detailing thetasks that must be completed anddocuments that must be submitted oravailable to prepare for a TfS audit.

Opening and Closing
Meeting Template

A presentation providing an overview of
the activities during an audit, which must
be used by auditors during the opening
and closing meetings of an audit.

Audit Guidance andReporting Template(AGRT) with Corrective
Action Plan (CAP)The document used by auditors to
conduct a TfS audit, and to record
subsequent corrective actions. The
document is also used to record progressagainst the actions in the event of anaudit follow-up.
A copy of the questionnaire can be madeavailable in PDF format by the TfS officeon request.

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Enhanced TfS (eTfS) Audit
Guidance and Reporting
Template (AGRT) with
Corrective Action Plan(CAP)

The document used by auditors to
conduct a TfS mining audit (see Annex 4)

The finalized audit report which is sharedwith TfS members, consisting of:•

TfS Audit Report••

After the Audit

DSA with the confirmation by theaudit company
The completed AGRT
Finalized bilingual CAP

Witness Auditor Checklist

A form to be completed during a witness
audit, documenting the performance of anauditor during the audit.

Witness Audit Process

Explanation and description of an witness
audit.

Confirmation by the Audit
Company (AC) form

Document to be signed by anindependent reviewer of the audit
company

1 Audit Objectives, Scope and Duration
1.1 Audit Objective
The objectives of the TfS Audit Program and the TfS Audits are to establish and maintain:• A review process suitable to raise suppliers' awareness about sustainability expectations
and requirements;• A consistent assessment of a supplier’s performance on key sustainability criteria and theimplementation of corresponding management systems;• A TfS Audit Report including a CAP (if needed) appropriate for suppliers to understandtheir performance and areas of improvement needed;

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A TfS Audit Report as a valid information source for sustainability information for buyers
to evaluate the business relationship with a supplier; andAn information basis for TfS members to individually and independently decide uponfurther actions to be taken supporting the supplier to improve its sustainability
performance.

The TfS Audit Program is not and must not be understood as:• A certification scheme• A compliance exercise with a pass or fail outcome

1.2 Audit Scope
The Audit Program and criteria are designed to focus on the key issues and risks related to raw
material, contract manufacture, and other product-related supplies for the Chemical Industry. TfS
members may apply the Audit Program to further supply categories, e.g. technical goods orpackaging.
For auditing mining operations with the enhanced TfS (eTfS) Audit, see Annex 4 of this document.
Applying TfS Audit standards, suppliers are assessed against nationally and internationallyrecognized standards (as detailed in Introduction: TfS Audit Program) and expected tocontinuously improve performance in the following areas:

Management✓ Management in Charge✓ Policy & Continual Improvement✓ Training✓ Business Partners

Environment✓ Environmental Compliance✓ Waste✓ Emissions to Air and Climate
Change✓ Water and Wastewater✓ Energy✓ Land Use and Biodiversity✓ Soil and Groundwater

Health and Safety Criteria✓✓✓✓

Product Safety
Transportation Safety
Process Safety and Storage
Occupational Health and Safety✓ Emergency Preparedness✓ Medical Care
✓ Security

Labor and Human Rights✓ Child Labor✓ Forced and Compulsory LaborVERSION 4.0✓ Freedom of Association✓ Discrimination
PAGE - 6 -Audit Objectives, Scope and Duration✓ Working Hours✓ Minimum Wages✓ Special Work Contracts✓ Facilities & Dormitories

Governance✓ Business Integrity✓ Privacy and Intellectual Property✓ Risk Area: Conflict Minerals✓ Risk Area: Animal Care
✓ Fair Competition✓ Disciplinary and Complaint
Procedures

The standards are the same for all suppliers and applicable no matter where they are located.
A TfS Audit typically covers a clearly defined supplier location or legal entity. In some cases, thephysical inspection can be specific to a plant/related infrastructure within the supplier location, forexample a production plant or warehouse location. The location which is to be in scope of theaudit must be agreed between the supplier and TfS member prior to the audit taking place andclearly defined by the supplier in the SFC and subsequently by the auditor in the TfS Audit Report.
The TfS Audit Report must contain an explanation which parts of the supplier site are not included
and why the audit excludes these parts (e.g. low sustainability risk profile, different location,
unforeseen circumstances leading to a limited audit time, access denied by supplier).
TfS will only conduct announced audits. The audits follow a defined series of steps encompassing
awareness raising, audit preparation, audit execution, CAP, audit report sharing, follow-up.

1.3 Multi-site audit
Since the 4.0 version it is possible to describe several audit sites in one report. The requirement
is that these share a common purpose (eg warehouse connected to a production facility, or
logistics).

1.4 Audit Duration & Lead-time
There are several factors determining the duration of a TfS Audit:✓✓✓✓

The number of employees and therefore the number of employee interviews
The supplier size (i.e. area of production facilities)
The nature and complexity of the operations
The diversity of tasks in the workplace might have an impact on the number of interviews(i.e. reducing the number when there is a high similarity).

A thorough preparation for the audit by the supplier is a key factor determining the efficiency andthus the time the auditor needs to collect the required evidence. The estimates shown in figure 2
below are based on the assumptions that suppliers actively support a thorough preparation of theaudit and that only one auditor is present. They do not include follow-up activities (desk reviews /on-site visits etc.).

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Figure 1: Guidance for duration based on the TfS AGRT Reporting Template

Size of the facility(excluding
management)

No. ofAuditor
Days

No. ofIndividual
Interviews

No. of GroupInterviews

Total No. of
Employees
Interviewed

Total No. of
Employeerecords

1-50
employees

13

1 group of 2
employees

5*5*50-1000
employees

25

2 groups of 5
employees each

15

15-20

above 1000
employees

310

3 groups of 5
employees each

25

25-30

* 5 employee interviews is the minimum requirement for a TfS audit.

An audit can be conducted by a team of two auditors within half of the “standard time”. In suchcases, a lead auditor must be defined who takes overall responsibility for the audit. Furthermore,
it is required that the two auditors take two independent audit streams to ensure the standard
audit time is spent effectively and covers all audit subjects to the required level of detail. Therefore,
the auditor team will split up after the opening meeting and will meet again in the afternoon tobriefly discuss and summarize their audit findings before the closing meeting starts.
The audit company has to ensure that a minimum number of interviews will be conducted as
described above. Deviations from these reference values have to be reported and explained in
the sheet “Audit Information” of the AGRT.
The following factors may influence the audit duration planning, amongst others:• Increasing factors are e.g. large site, large number of employees, high risk products/
processes, high complexity processes, high number of unique processes, enhanced
Audits (see Annex 4).
•

Reduction factors are e.g. small site, small number of employees, low risk products/
processes, less complex processes, high number of similar processes, no production onsite (office), Short Audits (see Annex 3).

If concerns are raised by employees during an audit, auditors must take the time to explore theseissues.
The typical lead-time for scheduling and audit from the day the contract is signed with the Audit
Company is 3 months.

1.5 Audit Cost
The supplier-paid model is a principle of TfS. The cost for a TfS Audit is negotiated between the
supplier and the TfS approved Audit Company. The cost can vary depending on many factors, for

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example the size and complexity of the facility being audited or the country in which the audit istaking place.

1.6 Combined Audits
In addition to sustainability topics, there may be other specific audit subjects relevant in a business
relationship such as product quality, quality management systems or regulatory compliance. The
TfS Audit can be combined with other audit subjects, contributing to an efficient approach for TfS
members as well as suppliers.
If a combined audit is conducted, the TfS Audit report produced must be completely separated
from other audit modules. The TfS audit process should be followed as detailed in this document,using the TfS AGRT, and must include the opening and closing meeting. Any matters beyond thesustainability topics (as described in section 1.2) are not part of the TfS Audit, must not bereflected in the TfS Audit report and will not be shared with TfS members.
A combined audit can be requested either by the supplier or by a TfS member. In both cases, it
is responsibility of the respective audit company to ensure that the TfS Audit is conductedaccording to the process and standards detailed in this document.
All requirements defined in this document, including the approval of auditors/ audit teams (asdescribed in section 2), have to be fulfilled in order to declare the sustainability audit to be a TfS
Audit.

1.7 Recognition of other audit standards
In some instances, TfS has recognized other audit standards as being equivalent to TfS Audits.
A list of these standards can be found in ‘Annex 2 – Equivalent auditing standards’.

2 Auditor Approval and Selection
2.1 Selection of Audit Companies
TfS Audits are conducted by qualified auditors from the approved audit companies, listed on the
TfS webpage. Suppliers can use this list to identify and select an audit company in their relevant
region to carry out a TfS Audit.
Before becoming an approved audit provider, audit companies are required to undergo an
approval procedure through the TfS Office to verify their credentials. During this process, internal
controls, quality management and evidence of proven records are considered. The final decisionon whether an audit company will be accepted rests with the TfS Steering Committee. TfS
monitors the collaboration with the audit companies on a regular basis and may decide on
accepting new audit companies or discontinuing the relationship with existing audit companies.

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Audit companies are expected to ensure only qualified and approved TfS auditors are deployed
for TfS Audits. A TfS specific auditor training program needs to be conducted by the audit
companies to provide the necessary background information and requirements with regard to the
purpose and objectives of the TfS initiative, as well as training on the audit process,documentation and follow-up. TfS approved audit companies may be requested to confirm andprovide evidence of according auditor trainings for example by sending the list of participants andtraining materials to the TfS Office.

2.2 Approval Process for Auditors
TfS requires auditors to prove competencies and experience in a range of sustainability relevant
aspects. Approved audit companies can nominate qualified auditors for the TfS approved auditor
pool. A set of reference criteria has been developed that serves as a basis for approving auditors
before they are able to conduct TfS Audits.
An Auditor Evaluation Form (AEF) is required to be completed for every new auditor proposed by
the audit company. The form sets out certain criteria with regard to the qualifications andexperience of the potential auditor and must be sent to the TfS Office for final validation
supplemented by proof of evidence to verify the information provided (e.g. CV, certificates, auditlog). If a potential auditor does not meet the minimum requirements, the TfS Office can request
the audit company to provide an alternative candidate. The audit company is welcome to resubmit the rejected auditors for approval at a later stage, if they have obtained additional
qualifications.
All TfS approved audit companies must ensure that even in peak times an adequate number ofqualified auditors is available to perform TfS Audits. If there is no auditor qualified or available inthe supplier country or region, the selected audit company must send further auditor profiles to
the TfS Office for approval. (Refer to section 2.3 for the approval criteria of auditors)

2.3 Approval Criteria for Auditors
Approved auditors must have achieved and maintain proven expertise in labor and humanrights, health & safety and environmental issues confirmed by:
•
•
•
•
•
•
•

Basic SA8000 auditor qualification and 10 social audits every 2 years performed (to beapproved for the social elements of a TfS Audit).
ISO 14001 and OHSAS 18001 training completed and 10 HSE audits every 2 years
performed (to be approved for HSE elements of a TfS Audit).
Being knowledgeable and up-to-date in applicable laws as well as international
standards with regard to social, ethical, and HSE audit subjects.
Chemical Industry experience (to be approved for Chemical Industry specific audits)
Familiar with local language and culture.
Good working knowledge of English language (written and spoken).
Qualified and trained for the TfS Audit Program (in accordance with section 2.1).

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Auditor Approval and Selection

TfS therefore requests audit companies to take these criteria into account when proposing anauditor for approval.
To cover all areas of sustainability, a TfS Audit can be performed by an audit team withcombined expertise in labor and human rights, health & safety and environmental issues.
Hence, auditors can be approved for either social or HSE aspects individually and join the teamfor their specific area of expertise. In this case, a lead auditor has to be named by the audit
company to take responsibility for the entire TfS Audit execution. The lead auditor has to ensurethat audit planning, audit execution, documentation and follow-up is performed in compliance withthe requirements defined in this guidance document.
The auditors’ performance will be monitored through audit report quality reviews conducted by
the TfS Office, and feedback provided by suppliers, witness auditors or TfS members.

2.4 Witness Audits
On a random sample basis, TfS members will conduct witness audits (observed audits). Thismeans audits will be accompanied by experienced staff assigned by the individual TfS member
according to the principles outlined in the TfS Witness Auditor Checklist. When requesting a TfS
Audit, TfS members will inform the supplier if they plan to conduct a witness audit. However, awitness audit requires the consent of the respective supplier. This information will be recorded in
the SCF and subsequently communicated to the TfS Office.
TfS requires all witness auditors to complete a Witness Auditor Checklist form in order to receivea systematic feedback on the audit preparation, audit process as well as the lead- and co-auditor
performance. This checklist evaluates the overall audit organization, the auditor and audit
performance.
Due to antitrust requirements, disclosure on the supplier relationship must be avoided while
sharing the results of the witness audits. Subsequently, witness auditors will report their findings
to the TfS Office only. Relevant statistics and information regarding auditor performance and theauditor pool will be established annually.

Annex 1: Glossary

Audit Guidance andReporting Template(AGRT)VERSION 4.0

TfS specific template for auditors to document the audit and findings.
Needs to be provided in English.

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Auditor Approval and Selection

AuditorA person appointed and authorized to deliver a qualified audit
judgment on the sustainability performance of the supplier. The
auditor may collect objective evidence by means of examination of
documents, interviews and site inspection.
For the purposes of TfS, auditors have to be qualified and approvedby the TfS Office. They must satisfy high quality criteria and meet therequirements defined in the auditor evaluation tool. A conflict ofinterest must be prevented in any cases.

Auditor Evaluation
Form

Excel tool that needs to be completed by the audit company for every
auditor in order to evaluate the auditor’s qualifications. Only auditorsthat have adequate qualifications will be part of the TfS approved
auditor pool.

Auditor Pool

Pool of auditors that have been approved by the TfS Office. Only
auditors that work for an accredited audit company can be part of the
TfS auditor pool.

Corrective Action

In the context of TfS, it refers to the implementation of measures orsystemic change to eliminate the cause(s) of an existing deviationfrom the criteria defined in the TfS AGRT and to prevent recurrence.

Corrective Action Plan(CAP)

The plan of actions drawn up by the supplier and agreed upon withthe auditor. It states the non-compliances identified during the audit
and what measures have to be taken within a certain time frame to
remedy these deviations from the criteria defined in the TfS AGRT.

Data Sharing
Agreement (DSA)

TfS specific form that documents suppliers’ consent to share the audit
report with all TfS members.

OASIS

Online Audit Sharing IT Solution (OASIS) is the online tool used bymembers to: nominate suppliers, invite them to prepare the audit,
access shared audits and upload shared non-TfS audits.
Suppliers access the tool to prepare their audit, send the request to
audit companies, update Corrective Actions and access their audit.

Enhanced Audits

Additional specific modules to Standard TfS Audit questionnaire (seeAnnex 4)

TfS Audit Follow Up

An on-site inspection or a desktop review aimed at the verification of
the closure of findings from the previous audit.

Short Audits

Suppliers in possession of an approved certificate are eligible toconduct a shorter version of the TfS audit; please send the certificate
and report for review to your requesting customer and the audit
company for verification of eligibility. See Annex 3 for full list of
approved certificates.

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Auditor Approval and Selection

TfS Assessment

A systematic process of collecting and analyzing data andinformation to determine the current status of the management
systems of an organization. The TfS initiative has contracted theservice provider EcoVadis to perform sustainability assessments anddevelop a CSR rating for supplier organizations.

TfS Audit

A methodical examination or review of a condition or situation. For
the purposes of TfS, the audits will verify environmental, health &safety and social conditions in the supply chain of TfS members,
against the TfS AGRT through an on-site inspection.

TfS Work Stream(s)The working groups of TfS composed of TfS member participants,
responsible for driving topics forward in the Initiative

TfS Mutual
Recognition Partner
List

The TfS Mutual Recognition Partner List summarizes the otherstandards that TfS has recognized as being equivalent to a TfS Audit.

TfS Steering
Committee

The executive body of the TfS Initiative composed of 7 CPOs of the
TfS Members, including the TfS President

Witness Audit

An audit that will be accompanied by experienced staff assigned by
the individual TfS member.

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Auditor Approval and Selection

Annex 2: Equivalent auditing standards••••

SQAS (Logistics Service Providers)
SMETA (full reports, 4 pillars)
PSCI (full report by external auditor, 4 pillars)
CRSAS(Logistics Service Providers in China)

Annex 3: Short Audits•

RCMS®/RC 14001® in the United States and Canada

Annex 4: Enhanced Audits•

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A4.1 Annex 4 – Enhanced TfS (eTfS) Audit

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Auditor Approval and Selection

Together for Sustainability
The Chemical Initiative for
Sustainable Supply Chains

Annex 4:Mining Module (eTfS Audit)
Version 1

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Auditor Approval and Selection

Table of contents
About this document............................................................................................................... - 2 Introduction: Together for Sustainability (TfS)......................................................................... - 2 Introduction: TfS Audit Program ............................................................................................. - 2 Documents and References ................................................................................................... - 3 1

Audit Objectives, Scope and Duration ......................................................................... - 5 1.1

Audit Objective ......................................................................................................... - 5 -1.2

Audit Scope.............................................................................................................. - 6 -1.3

Audit Duration & Lead-time ...................................................................................... - 7 -1.4

Audit Cost ................................................................................................................ - 8 -1.5

Combined Audits ...................................................................................................... - 9 -1.6

Recognition of other audit standards ........................................................................ - 9 -2

Auditor Approval and Selection ................................................................................... - 9 2.1

Selection of Audit Companies .................................................................................. - 9 -2.2

Approval Process for Auditors ................................................................................ - 10 -2.3

Approval Criteria for Auditors ................................................................................. - 10 -2.4

Witness Audits ....................................................................................................... - 11 -3

4

Audit Process and Responsibilities .................................. Error! Bookmark not defined.
3.1

Introduction to the Audit Process................................... Error! Bookmark not defined.

3.2

Roles and Responsibilities ............................................ Error! Bookmark not defined.
Guidance through the Audit Process ................................ Error! Bookmark not defined.

Step 0 Supplier Selection......................................................... Error! Bookmark not defined.
Step 1 Supplier Invitation ......................................................... Error! Bookmark not defined.
Step 2 TfS Audit Preparation ................................................... Error! Bookmark not defined.
Step 3 TfS Audit Execution ...................................................... Error! Bookmark not defined.
Step 4 Closing Meeting and Findings....................................... Error! Bookmark not defined.
Step 5 TfS Audit Report Sharing & CAP .................................. Error! Bookmark not defined.
Step 6 CAP Monitoring and Verification ................................... Error! Bookmark not defined.
Step 6.1 CAP Progress Monitoring .......................................... Error! Bookmark not defined.
Step 6.2 TfS Audit Follow Up .................................................. Error! Bookmark not defined.
5

Contact Details ................................................................ Error! Bookmark not defined.

Annex 1: Glossary ................................................................................................................ - 11 Annex 2: Equivalent auditing standards................................................................................ - 14 Annex 3: Short Audits........................................................................................................... - 14 Annex 4: Enhanced Audits ................................................................................................... - 14 VERSION 4.0

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Auditor Approval and Selection

A4.1 Annex 4 – Enhanced TfS (eTfS) Audit ............................................................................. 18
A4.2 eTfS Audit Objective and Scope ...................................................................................... 18
A4.2.1 eTfS Audit Objective .................................................................................................. 18
A4.2.2 eTfS Audit Scope....................................................................................................... 18
A4.2.3 Consistency Across Operations ................................................................................. 20
A4.3 eTfS Audit Duration .......................................................................................................... 20
A4.3.1 Engagement with the Community .............................................................................. 21
A4.3.2 Number of Auditors for eTfS ...................................................................................... 21
A4.3.3 eTfS Audit Cost ......................................................................................................... 22
A4.4 Guidance for Auditors on the eTfS AGRT ........................................................................ 22
A4.5 eTfS Auditor Approval and Selection................................................................................ 23

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A4.1 Annex 4 – Enhanced TfS (eTfS) Audit

A4.1 Annex 4 – Enhanced TfS (eTfS) Audit
This document provides guidance on auditing mining operations, as well as some general
information on audit good practice, when using the enhanced TfS (eTfS) Audit Guidance andReporting Template (AGRT). It is an annex to the TfS Audit Program and should be consulted incase a mining operation will be audited.

A4.2 eTfS Audit Objective and Scope
A4.2.1 eTfS Audit Objective
The objective of the eTfS Audit is to enable TfS members to audit mines against sustainability
standards and to address and evaluate mining specific concerns. The goal is to enable mines toimprove and engage in improvement actions regarding their sustainability performance.
In order to achieve this objective, TfS has developed an additional module that supplements thecore TfS Audit questionnaire (see Audit Program Guidance Document). The eTfS audit template
therefore contains an additional module with mining specific questions that enhances the core
TfS Audit questionnaire and program.
The questions and guidance in the eTfS AGRT refer to numerous internationally accepted mining
and other standards. In addition to the standards used to develop the core part of the TfS audit,
the following additional external references have been used to develop the eTfS Audit
questionnaire, amongst others:• the IFC Environmental and Social Performance Standard,• Voluntary Principles on Security and Human Rights,• UN Declaration on the rights of Indigenous Peoples• The Cyanide Code• The Initiative for Responsible Mining Assurance (IRMA)• UN Basic Principles on the Use of Force and Firearms by Law Enforcement Officials

A4.2.2 eTfS Audit Scope
The questionnaire is to be applied to opencast and underground mining operations and isintended to be globally applicable. The scope of the eTfS Audit is best applied to large scale
mining operations. It may be difficult for artisanal and small-scale mining (ASM) activities to fulfill
best practice standards designed for the formal mining sector.
The decision on which suppliers are to be audited against the eTfS module remains with theindividual TfS Member company. See “Step 0” in Section 4 regarding Supplier Selection in the
Audit Program Guidance document.
For some eTfS mining section questions, there may be an overlap with questions in the core partof the TfS AGRT (Management, Environment, Health and Safety, Labor and Human Rights,
Governance). The questions in the core TfS Audit part are relevant but not sufficient to covermining specific operations.
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A4.2 eTfS Audit Objective and Scope

It is expected that the mine not only complies with the local legislation, but aligns its operations,systems and processes with internationally accepted good or best practices. The questions andguidance in the eTfS refer to numerous internationally accepted mining and other standards.
Through the TfS process, suppliers are assessed against nationally and internationallyrecognized standards and expected to continuously improve performance in the areas outlined in
the table below. In the eTfS Audit, further criteria and focus areas specific to mining are included,
in addition to the topics in the core part of the TfS audit questionnaire:

TfS Audit
Management✓ Management in Charge✓ Policy & Continual Improvement✓ Training✓ Business Partners

Environment✓ Environmental Compliance✓ Waste✓ Emissions to Air and Climate
Change✓ Water and Wastewater✓ Energy✓ Land Use and Biodiversity✓ Soil and Groundwater

Health and Safety Criteria✓✓✓✓

Product Safety
Transportation Safety
Process Safety and Storage
Occupational Health and Safety✓ Emergency Preparedness✓ Medical Care
✓ Security

Labor and Human Rights✓✓✓✓

Child Labor
Forced and Compulsory Labor
Working Hours
Minimum Wages

✓
✓
✓
✓

Freedom of Association
Discrimination
Special Work Contracts
Facilities & Dormitories

Governance✓ Business Integrity✓ Privacy and Intellectual Property✓ Risk Area: Conflict Minerals

VERSION 4.0✓ Risk Area: Animal Care
✓ Fair Competition✓ Disciplinary and Complaint
Procedures

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A4.3 eTfS Audit Duration

Mining Module✓ Environmental, Social and Human
Rights management✓ Stakeholder and Rights Holder
Engagement✓ Labor and Working Conditions✓ Mine and Community health, andsafety✓ Security Arrangements✓ Land acquisition and involuntary
resettlement✓ Indigenous Peoples✓ Cultural heritage✓ Water Management✓ Mineral Waste and Water Holding
Facilities✓ Protected Areas, Biodiversity andEcosystem Services✓ Noise and Vibration✓ Greenhouse Gases / Climate Change✓ Substances of Concern: Cyanide andMercury Management✓ Local social and economic
development✓ Closure, rehabilitation and financial
planning✓ Compliance✓ Transparency✓ Supply Chain Management

A4.2.3 Consistency Across Operations
When auditing more than one operation for the same auditee, finding descriptions and finding
types should be checked for consistency, where there is a group approach to managing an aspectof the operations. Where there are differences in execution at site level and/or a different risk
profile, these differences should be documented, and the same finding type assigned wherefindings are similar.

A4.3 eTfS Audit Duration
Audits of mining operations will likely require more time than audits of other types of operations,both because of the scale and nature of mines (typically containing multiple mining and possible
beneficiation processes) and because of the additional questions in the mining section in the eTfS
AGRT. The table below is a guide for determining the time for conducting an eTfS Audit.
The following factors should be considered for determining the required on-site audit time:•Complexity of operations:o Extent of mining operations – e.g. opencast, underground, or both, and numberof pits or mine shafts; ando Extent of beneficiation/processing on site.
• Nature of the risks, considering sensitive receptors;• Specific complex issues where additional effort for one section is anticipated e.g. recent
fatality(ies), strikes, community action, contraventions that have resulted in closure,prosecution, political issues; andGeographical distance:

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A4.3 eTfS Audit Durationooo

to and between mining operations (pits, working areas underground) andbeneficiation processes that required significant driving or walking time,to and between communities and other sensitive receptors outside of the mineboundary (e.g. water courses, heritage sites, protected or sensitive flora/fauna
areas); anddistance from auditor accommodation, for example where mines are located in aremote area without onsite accommodation, requiring extensive daily travel).

Considering the additional complexity of auditing mining operations, there may be the possibility
that there is not enough time to complete a review of an issue during the audit. This should beclearly documented in the AGRT by raising it as a finding and providing further recommendationsin the CAP. The auditor should provide a full description of what was evaluated, and why aconclusion could not be made. The TfS Member can discuss with the supplier on what further
action may be required to complete the review.

A4.3.1 Engagement with the Community
Engagement with the members of the public, the community or other stakeholders should not be
undertaken unless permitted by the site and if time permits. Site visits to the area in which thecommunity resides or works, however, can be conducted, for example to inspect projects
funded/supported by the mine, or housing and associated utilities where resettlement has takenplace.

A4.3.2 Number of Auditors for eTfS
It is recommended to have up to three auditors who audit different focus areas (i.e. environment,
health and safety, and social). The audit company will decide on the number of auditors on acase-by-case basis dependent on the knowledge of the auditors conducting the audit and thepotential issues specific to the site to be audited.
For simple mine operations, two auditors may be considered, where one auditor has strong
competencies in two focus areas. This may also apply to complex mine operations; however threeauditors would likely be more suitable. Where fewer auditors are selected, additional audit time
may be necessary.
Table 3.1 Guidance for no. of auditors and audit duration (on site) based on the eTfS AGRT:
Mine Type

Description

Simple mine

Small, only opencast or underground, no or simple
beneficiation involving no / limited hazardous
chemicals, no or limited communities
Multiple processing/beneficiation processes,
opencast and underground mining, operations
and/or sites outside of mine boundary (community)
geographically spread out; complex and high risksocial, environmental or health safety issues

Complexmine

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No.
Auditors
2-3

2-3

No. days
on site3

4-5

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A4.4 Guidance for Auditors on the eTfS AGRT

A4.3.3 eTfS Audit Cost
The supplier-paid model is a principle of TfS. The cost for a TfS Audit is negotiated between the
supplier and the TfS approved Audit Company. The cost can vary depending on many factors,
for example the size and complexity of the facility being audited or the country in which the audit
is taking place.

A4.4 Guidance for Auditors on the eTfS AGRTFor the specific audit process steps and responsibilities, as well as the follow-up process,please refer to Section 4 of the Audit Program Guidance Document.
The auditor(s) should always ensure that there is consistency across the answers and finding
type where there is any overlap across the core TfS Audit questionnaire and the Mining section.
Comments based on evidence are required to support all findings, including when there are nofindings (either because the site is either considered fully compliant or the question is notapplicable).
Questions relating to policies, strategy, processes, procedures, programs and plans shall be
supplemented by a confirmation on whether the documents are being implemented. The auditor
should therefore review the actions the site has taken to fulfil the objectives of these documents
and assess whether the site can demonstrate their success in achieving the intended
objective(s).
Finding Type: Ensure that the finding description provides adequate detail to explain why thefinding is considered critical, major or minor, taking consideration of the guidance “Notes to the
Auditor”.
If there was insufficient evidence found by the auditor, a finding should be made in cases where
documentation has been requested but not been made available and is required to conclude thefinding.
When documenting the explanation of audit results, the auditor should make mention of the site’s
position on the issue and explain why the site considers the existing measures in place to beadequate. Furthermore, the auditor should provide clarity on why the recommended action (i.e.
application of an international standard or accepted practice) would be beneficial and decrease
any associated risks.
Conversely to the point above, it may be acceptable to the auditor that the site has not
implemented ‘best practice’ (that should be in place according to the respective eTfS questionand guidance) and has rather implemented ‘standard’ practice that is considered adequate, eventhough the site does not fully meet the TfS requirement. Here, the context of the organization isimportant. Context may include internal and external factors (e.g. existing relations with thecommunity, site and corporate culture). For example, the level of stakeholder engagement for an
operation where there is little community impact/involvement would be expected to be lower (andtherefore best practice not necessarily required), in comparison to one where there are many
communities that are directly impacted by the site’s operations. The auditor should take the

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A4.5 eTfS Auditor Approval and Selection

context of the mine into account when making a finding, ensuring the explanation of the finding
and finding type is explicit.

A4.5 eTfS Auditor Approval and Selection
For the selection of audit companies and the approval process of auditors, as well as additional
information on the criteria, please refer to section 2 of the Audit Program Guidance Document.

Approval Criteria for eTfS Auditors
Auditors should be able to demonstrate both audit skills, competence in the field they areauditing, an understanding of local legislation, and experience with the sector they are auditing.
In addition to the current qualification requirements for the core part of TfS Audits, the auditor
should be able to demonstrate experience evaluating operating mines against internationallyaccepted standards on environmental and social performance.

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