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SMETA audit checklist

SMETA Audit Preparation Checklist: 30 Things Every Indian Factory Must Do Before the Auditor Arrives

The auditor arrives tomorrow. Do you know where your fire drill records are? Can your workers explain the grievance procedure in their own words? Is your latest chemical disposal licence current?

For hundreds of Indian factories every year, these questions trigger panic — because SMETA audit preparation was treated as a last-minute scramble rather than an ongoing operational discipline.

Under SMETA 7.0, this approach is no longer survivable. With semi-announced audits now the norm and Management Systems Assessment (MSA) probing your everyday systems — not just your audit-day documents — factories that prepare properly and consistently are the ones that pass. Those that don’t, face non-conformances, buyer displeasure, and expensive re-audits.

This checklist from Greendot Management Solutions — built from 25+ years of on-the-ground experience with Indian MSMEs — gives you 30 concrete actions to take before your auditor walks through the gate.

Start at least 90 days before your audit — not 90 hours. First-time auditors: allow 90 days minimum. Renewal audits: allow 60 days. Semi-announced audits under SMETA 7.0: maintain permanent readiness

SECTION A: Documentation & Records

Documentation is the foundation of any SMETA audit. Auditors spend 30–40% of their time reviewing records. Gaps here trigger automatic non-conformances — regardless of what your actual practices are.

#DocumentWhat Auditors CheckCommon Gap in India
1Employment ContractsEvery worker has a signed contract in local language with pay, hours, leave, and notice period clearly statedContracts missing for contract/temporary workers
2Wage & Payslip Records12 months of payslips showing basic, OT, deductions — cross-checked against bank statementsWage records show round figures; no OT breakdown
3Attendance & Working Hours LogsDaily attendance vs payroll; OT hours must not exceed legal limits; 1 day rest in 7Biometric data not maintained; manual registers have corrections
4Age Verification DocumentsDOB proof for all workers — especially those appearing young — to confirm no child labourNo age proof for casual / daily wage workers
5Labour Licences & Statutory RegistrationsFactories Act licence, ESIC, EPFO, Contract Labour licence — all current and displayedLicences expired or not renewed after workforce increase
6Health & Safety PolicySigned by MD/CEO, dated, posted in local language, communicated to all workersPolicy exists but is 5+ years old and never updated
7Accident & Near-Miss RegisterAll incidents logged with date, nature, injury, corrective action — for minimum 3 yearsOnly major accidents recorded; near-misses not tracked
8Fire Drill & Emergency RecordsAt least 2 fire drills per year, with dates, attendees, and findings documentedLast drill was before previous audit — 18 months ago
9Training RecordsH&S induction for every new worker; ongoing training evidence with signaturesTraining done verbally; no attendance sheets or records
10Grievance RegisterLog of all complaints raised, by whom (role, not name), action taken, resolution dateGrievance box exists but is never opened; no register maintained

SECTION B: Health, Safety & Facility Compliance

#AreaWhat Auditors CheckCommon Gap in India
11Fire Safety EquipmentExtinguishers — correct type, serviced annually, accessible, not blocked. Hydrants functional.Extinguishers last serviced 3+ years ago; some discharged
12Emergency Exits & SignageAll exits clearly marked in local language, unlocked during working hours, unobstructedExit doors locked from inside; signage only in English
13Machine GuardingAll moving parts guarded; guards cannot be bypassed; PPE posted at each machineGuards removed for ‘efficiency’; no lockout/tagout procedure
14PPE Availability & UsageCorrect PPE available, in good condition, workers trained to use it, usage actually observedPPE is stored, not worn; workers claim it is uncomfortable
15First Aid FacilitiesStocked first aid box, first aider identified and trained, records of use maintainedBox has expired items; no trained first aider designated
16Welfare FacilitiesClean drinking water, functional toilets (ratio to workers), canteen/rest area if applicableSeparate male/female toilets missing; water coolers not maintained
17Chemical Safety (MSDS/SDS)SDS for every chemical, in local language, accessible at point of use, workers trainedSDS in English only; workers unaware of chemical hazards
18Electrical SafetyNo exposed wiring; switchboards enclosed; earthing certificates current; no overloadingExtension cords overloaded; no annual electrical safety audit

SECTION C: Worker Awareness & Rights

This is where most Indian factories lose points. Auditors conduct confidential worker interviews — and what workers say matters enormously. Coaching workers is strictly prohibited and considered an integrity violation.

#What Workers Must KnowHow to Prepare
19Their own wages and deductionsConduct monthly team briefings where HR explains payslips. Workers must understand basic, OT, PF, ESI, and net pay.
20Their working hours and OT entitlementPost shift timings on notice boards. Brief all workers on daily hours, weekly rest, and OT calculation method.
21How to raise a grievance — and feel safe doing soTest your grievance mechanism: does it work? Are workers comfortable using it? Post grievance process in all languages spoken in the factory.
22Their right to leave and not be penalisedEnsure workers know their earned leave, sick leave, and casual leave entitlements. Check that managers don’t penalise workers for taking legitimate leave.
23Basic H&S rules, emergency procedures, and who to report toConduct quarterly H&S awareness sessions. Workers should be able to name the fire assembly point, the first aider, and the grievance officer.

Never Coach Workers What to Say to Auditors

Instructing workers on how to respond to auditor questions is treated as a serious integrity violation under SMETA 7.0.

If auditors discover coached responses, it results in automatic Critical findings and can trigger buyer rejection of the audit report entirely. The right approach: fix the actual conditions, train workers on their rights, and let them speak truthfully.

SECTION D: Environment (4-Pillar Audits)

If you are undergoing a 4-Pillar audit, these four areas are consistently the most common source of non-conformances in Indian pharma, chemical, and engineering factories.

#AreaPreparation Action
24Environmental Licences & ConsentsCheck expiry dates on all environmental licences — consent to operate, effluent discharge, hazardous waste authorisation. Renew any that are within 3 months of expiry.
25Waste Manifest & Disposal RecordsMaintain a waste inventory register. Ensure all hazardous waste has a licensed disposal vendor with current agreement. Keep all waste manifests for minimum 3 years.
26Energy & Water Usage DataCompile 12 months of electricity bills, fuel consumption, and water usage records. If no tracking system exists, begin now and at minimum document the last 3 months.
27Environmental Management PolicyCreate a 1-page Environmental Policy signed by the MD. Assign a named Environmental Manager. Post the policy in the factory in local languages.

SECTION E: Business Ethics (4-Pillar Audits)

#AreaPreparation Action
28Anti-Bribery & Corruption PolicyDraft a formal Anti-Bribery and Anti-Corruption Policy. Have it signed by the MD, dated, communicated to all employees, and posted on the notice board.
29Whistleblower / Speak-Up MechanismEstablish a confidential reporting channel (a suggestion box, a helpline number, or a named ethics officer). Ensure workers are aware of it and trust it.
30Code of Conduct & Sub-supplier DisclosureCreate a Code of Conduct document for employees. Identify and disclose all sub-suppliers, contract manufacturers, and home workers in your Sedex account.

Recommended Preparation Timeline

90 Days Before: Complete gap analysis against all 30 checklist items. Priorities Critical and Major gaps.
60 Days Before: Fix all Critical gaps. Begin documentation upgrades. Conduct first worker awareness session.
30 Days Before: Conduct mock audit. Brief all department heads. Verify all licenses and permits are current.
7 Days Before: Final document review. Ensure workers know their rights. Confirm auditor logistics. Audit Day: Be transparent, be cooperative, answer honestly

Frequently Asked Questions

Q1: What happens if the auditor finds a non-conformance?

Non-conformances are normal — especially in first audits. You receive a Corrective Action Plan (CAP). Critical findings must be resolved immediately. Major findings within 30–60 days. Minor within 90 days. Upload evidence on Sedex. Your buyer monitors your CAP closure in real time.

Q2: Can I do a pre-audit myself without a consultant?

Yes. Use this 30-item checklist as your internal pre-audit tool. Walk through every area, document what is in place, identify gaps, and assign an owner and deadline to each gap. For higher-stakes audits or first-time audits, a professional mock audit with a consultant is strongly recommended.

Q3: Do workers need to be told the audit is happening?

Semi-announced audits — where the factory is given a short window (typically 24–48 hours) of notice — are now the preferred model under SMETA 7.0. Unannounced audits are also possible. You cannot guarantee full advance notice. This is why permanent readiness is the only sustainable strategy.

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