Ethical audits that hold up when the buyer checks
An ethical and social compliance audit checks how a site treats the people who work for it, against South African labour law and the buyer’s code. ASC runs these as preparatory or second party audits: one day on site, report within two weeks. ASC is not a certification body, and not a SIZA or SMETA approved audit company.
Auditing is charged hourly and a full programme is quoted on scope once ASC has seen the site. ASC will tell you before the quote if the work is smaller than you think.
An ethical and social compliance audit asks a different question from a food safety audit. A food safety audit asks whether the product is safe. An ethical audit asks whether the people who made it were employed lawfully and treated decently, and whether the site can prove it from its own records. For a South African producer, pack house or manufacturer selling into the United Kingdom or European Union, the second question now settles listings as firmly as the first does.
Retail buyers no longer take a supplier’s word on labour practice. They require independently verified assurance before they will list product or renew a supply agreement, and the report travels further than the site does: a buyer’s technical team reads the non compliance list and forms a view of the business long before anyone visits.
An ASC ethical audit is the one you commission for yourself first: a preparatory or second party audit conducted to ISO 19011, the international guidelines for auditing management systems, looking for the findings an approved audit body would raise while the practice can still change. ASC is not a SIZA approved audit body and not a SMETA approved audit company, so the report carries no standing with SIZA, Sedex or a retailer scheme. A critical finding in a third party audit can suspend a supply relationship mid season. The same finding raised here costs a corrective action and a payroll cycle to evidence.
What most ethical audit reports miss, and what ASC does instead
Most ethical audit reporting is a document sighting exercise dressed as an investigation. The auditor confirms that the contract file, the payroll and the attendance register exist, and writes a clause number beside a tick. Worker interviews come late in the day, in a room the client chose, with a supervisor within earshot. The report tells the buyer that the site keeps files, not what happens to a seasonal picker on a Friday in the middle of harvest.
Documents are the easiest part of an ethical system to produce and the hardest to trust alone. A signed contract proves a contract was filed, not that the worker received a copy, understood the language, or was paid on those terms. The finding that fails a site is the one where the document and the worker’s account of the same week do not reconcile, and SIZA’s published audit methodology treats that kind of inconsistency as a critical non compliance.
ASC audits the practice and uses documents as evidence for or against it. The sample is built before the site knows which files will be pulled, stratified across contract type, shift, gender, home language and each labour broker separately. The evidence is then reconciled: clock records against payroll, payroll against payslips, payslips against what the worker says was received. Where they disagree, the disagreement is the finding. The report is never dressed up as more than it is, because a buyer who catches a supplier passing a consultant’s report off as a scheme audit draws a lasting conclusion.
Key facts at a glance
When a business calls ASC in
- A United Kingdom or European retailer or importer has made an ethical audit a condition of listing, and the site has never been audited on labour practice.
- A third party social audit is booked, and management wants to know which findings would come out as major or critical while there is time to act.
- A previous audit closed with corrective actions signed off on paper, and nobody is confident the change held on the floor.
- The site uses labour brokers or seasonal intake and cannot show what those workers are paid or how long placements have run.
- A buyer wants a second party audit of its supplier base and needs somebody competent to visit a grower and report back.
- The business houses workers on the property and wants to know its position on living conditions and occupier rights.
How ASC does the work
1
Scoping the site, and the records that get pulled
The audit begins before the visit with an employment profile: headcount by department, contract type and shift, the permanent, fixed term and seasonal split, every labour broker in use, the languages spoken on site, and whether the employer provides housing or transport. ASC builds the sampling plan from that, and requests records across twelve consecutive months so that peak season, low season and a public holiday period are all read.
The record set runs from written particulars of employment and payslips through clock records, overtime authorisations, leave and age verification registers, the grievance and disciplinary register, committee minutes and the labour broker agreement with its placement records. Each proves one narrow thing: a contract file proves what was recorded, not what was paid.
2
Wages, deductions and hours, reconciled rather than sighted
Every worker has a right to the national minimum wage under the National Minimum Wage Act 9 of 2018. The rate is reviewed and adjusted, so confirm the rate in force rather than rely on last season’s figure. Transport, food, accommodation, allowances, tips and bonuses cannot be counted towards it, and deductions are tested against the consent and limit requirements of the Basic Conditions of Employment Act 75 of 1997.
Hours are reconciled, not read. The Act limits ordinary hours to 45 hours in any week and overtime to 10 hours a week, and requires meal intervals and rest periods. ASC follows selected workers through one week end to end: clock in and out, hours computed, overtime rate applied, payslip issued, amount paid.
3
Worker interviews, run so that a worker can actually speak
The sample is drawn from workers present on the day, stratified so that seasonal workers, night shift, women, workers placed by each labour broker and workers who live on the property are represented rather than averaged away. Interviews are held out of earshot of supervisors. No manager is present and no manager interprets, and the interview is held in the worker’s own language, whether that is isiXhosa, isiZulu, Afrikaans, Sesotho or Sepedi.
Taking part is voluntary, and answers are reported as themes, never attributed. The auditor tests each document against lived experience: not whether a contract exists, but whether the worker received one and in what language; not whether payslips are issued, but whether the worker can say what the deductions are for; not whether a grievance procedure is written down, but who the worker would actually go to.
Interviews carry the subjects no file settles: whether workers know they may join a union or elect representatives under the Labour Relations Act 66 of 1995, whether the worker committee meets and records its decisions, whether pay and promotion show the discrimination the Employment Equity Act 55 of 1998 prohibits, and whether child or forced labour could enter through seasonal or brokered intake.
4
Labour brokers and temporary employment services
Labour broker arrangements are where South African ethical audits most often find real exposure, because the site’s payroll is clean and the risk sits one contract away. Section 198 of the Labour Relations Act 66 of 1995 makes the temporary employment service and the client jointly and severally liable where the service contravenes a collective agreement, an arbitration award, the Basic Conditions of Employment Act or a sectoral determination. Section 198A deems a placed worker earning below the Basic Conditions of Employment Act threshold, whose placement runs beyond three months and is not a genuine substitution for an absent employee, to be the client’s employee on an indefinite basis.
The audit therefore follows the worker rather than the payroll. ASC asks who is on site today, not who is on the wage register, and traces brokered workers through the broker’s contracts, payslips and proof of payment against the site’s gate and clock records. A broker’s refusal to release payroll evidence for people on the client’s premises is a finding against the client.
5
Health, safety, facilities and worker accommodation
Health and safety is audited against the Occupational Health and Safety Act 85 of 1993 and its regulations: the section 16(2) assignment of duties, health and safety representatives and committee minutes, risk assessments, machine guarding, chemical handling, protective equipment issued and actually worn, and first aid boxes and appointed first aiders under the General Safety Regulations. The Facilities Regulations of 2004 add sanitation with free toilet paper and soap, running hot and cold water, drinking water and gender separated changing facilities.
Where the employer provides accommodation, living conditions and tenure both form part of the audit. The Extension of Security of Tenure Act 62 of 1997 gives an occupier residing on land belonging to another with consent the rights to dignity and privacy, to family life according to their culture, to receive visitors at reasonable times, to water and to health and education services. An eviction requires an order of court.
6
Corrective action, closure, and why closure takes a payroll cycle
A minor finding is an isolated lapse presenting low risk. A major finding is a systemic breach, or one that puts workers at risk. A critical finding is the category that stops a supply relationship: child labour, forced labour, physical abuse, workers not being paid at all, an imminent danger to life, or an attempt to influence the audit.
Closure follows evidence, never assertion. A revised policy is not a closed finding, and a training register signed on the day of the audit is not proof that practice changed. Practice is evidenced by records generated after the change: a wage finding closes on the payslips of the next full pay period, an hours finding on a completed cycle of clock and overtime records. Where a site is heading for a third party audit, ASC also offers SIZA implementation consulting to build the underlying management system.
How ASC helps, in practice
The following are illustrative composites of the situations this work involves. They name no client and report no measured outcome.
A pack house facing its first buyer mandated ethical audit
A United Kingdom importer made a social audit a condition of the season. The pack house had contracts on file and a payroll bureau, and believed it was in good shape.
ASC ran a one day preparatory audit across permanent staff, seasonal intake and two brokers, interviewing privately in isiXhosa and Afrikaans. Seasonal workers had signed nothing they could describe, payslips carried a deduction no worker could explain, and the grievance register held two entries for a workforce that peaked in the hundreds.
The site received a graded finding list, a wage and hours reconciliation it could rerun itself, and a plan sequenced so the wage and contract items would be evidenced by the next pay period.
A labour broker arrangement the paperwork hid
A processing plant used a broker for line staff during peak, and nobody had read the placement dates.
ASC traced brokered workers through gate records, the broker’s contracts and its proof of payment, and interviewed them separately. Several placements had run well beyond three months, the workers earned below the Basic Conditions of Employment Act threshold, and no payslips existed for two of them.
The report set out the section 198A deeming position and the liability under section 198, and the client took a written position on each long running placement.
Accommodation that had never been audited
A farming operation housed workers and their families on the property, with an accommodation deduction on the payroll.
ASC inspected the dwellings for water, sanitation, electricity and overcrowding, checked the deduction against the wage testing, and asked occupiers privately about visitors and about their right to remain if employment ended.
The audit produced a housing condition schedule, a corrected position on the deduction, and a written note of the occupier rights under the Extension of Security of Tenure Act 62 of 1997.
What you receive
| Deliverable | What it contains |
|---|---|
| Ethical audit report | Findings by subject area against South African labour law and the applicable code of conduct, each with the evidence examined, the section or clause engaged, and a grading of minor, major or critical. |
| Corrective action plan | Every finding with root cause, the agreed action, the responsible person, a due date set against the payroll and season calendar, and the evidence that will close it. |
| Wage and hours reconciliation | A worked comparison of clock records, payroll, payslips and payments for selected workers and pay periods, set out so the site can repeat the test itself. |
| Worker interview summary | Themes from the sample, reported so no individual can be identified, with sample composition shown by contract type, shift, gender, language and labour broker. |
| Document and records register | What was requested, what was produced, what was missing, and the retention position against the record keeping requirements of the Basic Conditions of Employment Act 75 of 1997. |
| Readiness position | ASC’s assessment of which findings an approved audit body would be likely to raise as major or critical, and what must change before the business books that audit. |
The rest of the ASC audit programme
Ethical auditing usually sits alongside food safety and farm assurance work on the same site.
Other ASC audits
One audit team, one method, across the whole programme.
Build or fix the system
Where the audit finds a gap, ASC implements the fix with your team.
Train and equip
Online courses and editable document toolkits.
Who this work suits
ASC works across the sectors that sell into audited supply chains: deciduous and citrus growing and packing in the Eastern and Western Cape, table grape and wine farming, subtropical fruit in Limpopo and Mpumalanga, vegetable and potato production, and the pack houses and cold stores that serve them. In manufacturing the work covers fish and seafood processing along the coast, poultry and red meat abattoirs, dairy, bakery and confectionery, beverage bottling, and the contract packers who fill retailer own brand lines.
The practice is based in Gqeberha, formerly Port Elizabeth, in Nelson Mandela Bay in the Eastern Cape, with teams in Johannesburg and Cape Town and on site teams in Durban and across South Africa, led by lead auditors registered with SAATCA, Exemplar Global and IRCA. ASC is SAATCA registered, a FoodBev SETA Accredited Provider No. 587/00337/1900.
Where ASC stops
ASC is not a certification body and never certifies a management system. The certification decision belongs to an accredited certification body after its own third party audit, and no work ASC does can substitute for that decision or influence it.
The boundary is firmer still in ethical auditing. ASC Consultants SA is a member of the Sustainability Initiative of South Africa, membership number 20240910 112270, which is membership of the programme and nothing more. ASC is not a SIZA approved audit body and is not a SMETA approved audit company. An ASC ethical audit produces no rating, letter or record on any scheme platform and carries no standing with SIZA, Sedex or a retailer scheme.
Frequently asked questions
Can ASC conduct our SIZA or SMETA audit?
No. ASC is not a SIZA approved audit body and not a SMETA approved audit company, and will not present its work as either. SIZA social audits are conducted by audit firms SIZA recognises, and SMETA audits by audit companies Sedex approves. ASC provides the preparatory audit before that visit, or a second party audit for a buyer against its own code. ASC Consultants SA holds SIZA membership, number 20240910 112270, which confers no authority to audit for it.
What is the difference between an ethical audit and a food safety audit?
A food safety audit examines whether the product is safe. An ethical audit examines whether the people who made it are employed lawfully and treated decently: contracts, wages and deductions, hours and leave, freedom of association, child and forced labour, discrimination, grievance procedure, health and safety, and living conditions where the employer houses workers.
Why must management stay out of worker interviews?
Because a worker who is watched gives the answer that is safe rather than the answer that is true. Recognised social audit methodology holds that no manager should be present during worker interviews and that management should not act as interpreters. ASC applies that without exception.
Which findings recur most often on South African sites?
Described as patterns rather than counts: seasonal and brokered workers who never received written particulars of employment they can understand; payslip deductions no worker can explain; overtime that appears in production records but not in the attendance register; grievance registers almost empty on a large workforce; age verification held for permanent staff but not for seasonal intake; and broker placements that have quietly run past three months.
How long does the audit take and when do we get the report?
An ASC ethical audit is one day on site. Findings are presented to management the same day at a closing meeting, so nothing in the written report arrives as a surprise. The final report follows within two weeks of that meeting. Auditing is charged hourly, and a full programme is quoted on scope once ASC has seen the site.
Is the report confidential, and can we show it to a buyer?
The report belongs to the client who commissioned it, and ASC does not upload it to any platform or share it with a buyer, a scheme or a retailer. Clients may share it themselves, but it must be shared for what it is: a preparatory or second party report, not a scheme audit.
Find the findings before the buyer’s auditor does
Send ASC your employment profile, your labour broker arrangements and the date of the audit you are preparing for, and the site visit can be scoped from there. A conversation before the season costs far less than a critical finding during it.
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