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Compliance Assessment Report Jie Cai Plastic Toys Manufacturing Ltd (L-526) Audited on August 16, 2011 Page 1 of 11 NBCUniversal Confidential Report Date: August 19, 2011 Audit Date: August 16, 2011 Factory ID number: L-526 From: Jane Zeng/URS Consulting (Shanghai) Ltd. Cc: Parul Chandra/NBCUniversal Karen Tiongson/NBCUniversal Susan Feder/NBCUniversal Sophie Zhao/NBCUniversal Subject: Summary of Findings - Supplier EHS Audit J Audit type: Initial Audit This report summarizes the findings of the Environment, Health and Safety (EHS) Audit conducted at the facility of Plastic Toys Manufacturing Ltd located at the Sixth Building, Bao Ma Road, Shui Bian Village, Heng Li Town, Dongguan City, Guangdong Province, Peoples Republic of China. The findings of the EHS Reviews were based upon a review of the documents furnished by Jie Cai Plastic Toys Manufacturing Ltd and the observations obtained by URS Consulting (Shanghai) Ltd. on behalf of NBCUniversal during the site visit on August 16, 2011. For the purpose of this audit, the facility of Jie Cai Plastic Toys Manufacturing Ltd is referred to as the Site in this report. Guidance: The Compliance Assessment Report summarizes the Site audit findings and includes a corrective, and preventative action plan that both the Auditor and the Site Manager believe is reasonable to ensure conformity with the country specific and local laws. NBCUniversal (NBCU) upholds a worldwide reputation for integrity and high standards of business conduct. NBCU Supplier Relationship Policy requires that we source only from suppliers who comply with local laws and any applicable NBCU standards in such areas as labour, environment, health and safety. In order to ensure compliance with applicable laws and company policies please provide evidence of closure on all open red findings within 90 days from receipt of report. If you have any questions about the memorandum please contact the following persons: Ms. Karen Tiongson / NBCUniversal , and Ms. Jane Zeng/URS Consulting (Shanghai) Ltd. , on behalf of NBCUniversal. Compliance Assessment Report Jie Cai Plastic Toys Manufacturing Ltd (L-526) Audited on August 16, 2011 Page 2 of 11 NBCUniversal Confidential Supplier General Information Licensee/Vendor Company Name Medicom Toy Corp License/Vendor Company Contact Name/Email Waivers from Government None Certifications received from Government or other Companies. None Principal Products Manufactured Plastic Toys Annual Output of Products Approximately 2,000,000 pieces per year Major Customers Medicom, Kidrobot and NBCUniversal Production Process Injection Molding, Rotocasting, Painting, Printing and Packing Factory Normal Working Days and Normal Work Hours Five days a week Painting and Printing: one shift a day (7:4511:45, 13:4517:45) Packing and Office: one shift a day (8:0012:00, 14:0018:00) Departments that run more then one shift Injection molding: three shifts a day (8:0016:00, 16:0024:00, 24:008:00) Rotocasting: two shifts a day (8:0016:00, 16:0024:00) Peak Production Months None Number of Production Buildings Two production buildings (Building A and Building B) Compliance Assessment Report Jie Cai Plastic Toys Manufacturing Ltd (L-526) Audited on August 16, 2011 Page 3 of 11 NBCUniversal Confidential Canteen/Cafeteria Services The Site has two canteens which are separately located on the first floor of earch dormitory building Dormitories Two dormitory buildings (Dormitory A and Dormitory B) Security The Site has 20 full-time security persons working 24 hours a day in 2 shifts. Overall findings In view of findings raised, non compliances were observed in workshops, air compressor room and lubricating oil storage area. Details of the findings are listed below. For all other areas, no violations or non compliances were noted. Findings Total Findings Black Flags - 0 Red Flags - 2 Yellow Flags - 11 Permits - the following government documents and permits were provided for review. 1. Safety Training Certificates (Mr.Wu Haoming and Mr. Zhong Nanfang), issued in 2008 and 2009 2. Environmental Impact Assessment (EIA) and its approval, 2008 3. Environmental Impact Assessment (EIA) and its approval, 2010 4. Environmental Protection Check and Acceptances (EPCA) and its approval, 2009 5. EPCA Monitoring Reports, 2009 and 2010 6. Hazardous waste disposal license and transfer manifests 7. Hazardous waste disposal agreement, valid from May 2011 to May 2012 8. Occupational Health Examination Reports, 2011 9. Hygiene Monitoring of noise and indoor air, June 2011 10. Hygiene Permit for Canteen, issued in 2009 11. Special Equipment Inspection Reports of two lifts and air compressor accessories, 2010 12. Work Permit of one pressure vessel operator, two lift operators and two electricians 13. Fire Protection Check and Acceptance (FPCA), 2008 and 2009 Audit Score Percentage and Audit Re-extension Status Audit score will be presented in the final report. Background In 2002, Ya Bao Plastic Toys Manufacturing Ltd (“Ya Bao”) was set up in Changping Town. In December 2007, the site changed their factory name from “Ya Bao Plastic Toys Manufacturing Ltd” to “Jie Cai Plastic Toys Manufacturing Ltd” (“Jie Cai”) and moved to Hengli Town. In August 2008, Jie Cai leased the site area and started its production. Jie Cai is surrounded by an electronic factory, roads and vacant lands. No environmental sensitive receptors are located immediately adjacent to the Site. Compliance Assessment Report Jie Cai Plastic Toys Manufacturing Ltd (L-526) Audited on August 16, 2011 Page 4 of 11 NBCUniversal Confidential The Site covers a total area of about 6,000 square meters and comprises one 3-storey production building and 4-storey production building. Ancillary buildings at the site mainly include two 5-storey dormitory buildings, three single-storey warehouses and one guide room. The Site consumes plastics (ABS, PVC, PP etc) as its raw materials. Chemicals used at the site mainly include paint, ink, thinner, glue, ethanol, lubricating oil and diesel oil. EHS Management: Mr. Zhong was appointed to take charge of general EHS affairs of the Site. The Site has two persons (Mr. Zhong and Mr. Wu) who obtain safety training certificates from the local Work Safety Bureau. Employee Interview: Number of Selected Employees: The Site has 814 payroll employees. A total of 10 employees (about 1.2% of the total staff) were selected for the worker interview, but 1 of them took a leave during the audit. Age Groups/Gender: Of the interviewed employees, 2 were 19 years old, 3 were 20-30 years old, 2 were 30-40 years and 2 were 40-50 years old, including 7 females and 2 males. Employment Period: Of the interviewed employees, 4 have worked for about six months, 3 have worked for about one year and 2 have worked for about two years. Operational Activities: The interviewed workers were selected from injection molding, rotocasting, painting, printing and packing processes, which covered most of the processes and jobs at the Site. Finding Numbers: 4.3a Best Practices: The Site conducts fire drills twice a year, relevant records are well filed. Documents and policies of human rights were communicated with employees via posters and staff trainings. Closing Meeting: A closing meeting was held to conclude the audit and introduce the follow-up procedure. The factory representatives (Mr. Ivoy Yau, Ms. Echo Lee, and Mr. Zhong Nanfang etc) and auditor (Ms. Jane Zeng) attended this meeting. All findings were confirmed by the Site representatives. They expressed that they were willing to follow the relevant requirements of NBCUniversal and will strive to close the findings as soon as possible. Compliance Assessment Report Jie Cai Plastic Toys Manufacturing Ltd (L-5
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