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Auditee : Shenzhen Zhaoyang Electronic Technology Co.,Ltd. Audit Date From : 18/11/2016 Audit Date To : 18/11/2016 Expiry Date of the Audit : Please refer to the producer profile in the BSCI platform Auditing Company : TUEV SUD Auditor’s Name(s) : Scarlet Yi Wang(Lead) Auditing Branch (if applicable) : TUV SUD China This is an extract of the on line Audit Report.The complete report is available in the BSCI Platform. Access www.bsciplatform.org, for entitled users only. All rights reserved. No part of this publication may be reproduced, translated, stored in a retrieval system, or transmitted, in any form or by any, means electronic, mechanical, photocopying, recording or otherwise, be lent, re-sold, hired out or otherwise circulated without the FTA’s consent. This is an extract of the BSCI Audit Report, which is available in the BSCI Platform. © Foreign Trade Association (FTA), 2013 - The English version is the legally binding One. Created with EO.Pdf for .NET trial version. http://www.essentialobjects.com. Producer : Shenzhen Zhaoyang Electronic Technology Co.,Ltd. DBID : 364261 and Audit Id : 70004 Audit Date : 18/11/2016 Audit Type : Full Audit Page 1/12

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Auditee : Shenzhen Zhaoyang Electronic Technology Co.,Ltd.

Audit Date From : 18/11/2016

Audit Date To : 18/11/2016

Expiry Date of the Audit : Please refer to the producer profile in the BSCI platform

Auditing Company : TUEV SUD

Auditor’s Name(s) : Scarlet Yi Wang(Lead)

Auditing Branch (if applicable) : TUV SUD China

This is an extract of the on line Audit Report.The complete report is available in the BSCI Platform. Access www.bsciplatform.org, for entitled users only.

All rights reserved. No part of this publication may be reproduced, translated, stored in a retrieval system, or transmitted, in any form or by any, means electronic, mechanical, photocopying, recording or otherwise, be lent, re-sold, hired out or otherwise circulated without the FTA’s consent.

This is an extract of the BSCI Audit Report, which is available in the BSCI Platform. © Foreign Trade Association (FTA), 2013 - The English version is the legally binding One.

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Producer : Shenzhen Zhaoyang ElectronicTechnology Co.,Ltd.

DBID : 364261 and Audit Id : 70004 Audit Date : 18/11/2016

Audit Type : Full Audit

Page 1/12

Rating Definitions

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Producer : Shenzhen Zhaoyang ElectronicTechnology Co.,Ltd.

DBID : 364261 and Audit Id : 70004 Audit Date : 18/11/2016

Audit Type : Full Audit

Page 2/12

Main Auditee Information

Name of producer : Shenzhen Zhaoyang Electronic Technology Co.,Ltd.

DBID number : 364261

Audit ID : 70004

Address : North Unit, 3rd Floor, 6th building, Shaxia Industrial Park, Minzhi Boulevard, Longhua New District ShenzhenCity

Province : Guangdong Country : China

Management Representative : Rong XU

Contact person: Rong XU Sector : Non-Food

Industry Type : Mechanical and electrical engineering Product group : Transport and automotive

Product Type : LED Lightings and LED AutomotiveLamps

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Producer : Shenzhen Zhaoyang ElectronicTechnology Co.,Ltd.

DBID : 364261 and Audit Id : 70004 Audit Date : 18/11/2016

Audit Type : Full Audit

Page 3/12

Audit Details

Audit Range : Full Audit Follow-up Audit

Audit Scope : Main Auditee Main Auditee & Farms

Audit Environment : Industrial Agricultural

Audit Announcement : Fully-Announced Fully-Unannounced Semi-Announced

Random Unannounced Check (RUC) : No

Audit extent (if applicable) : none

Audit interferences or contingencies (if applicable) : none

Overall rating : C

Need of follow-up : Yes If YES, by : 18/11/2017

Rating per Performance Area (PA)

PA 1 PA 2 PA 3 PA 4 PA 5 PA 6 PA 7 PA 8 PA 9 PA 10 PA 11 PA 12 PA 13

B C A A A D B A A A A B B

Executive summary of audit report

Location and size]: The factory starts their operation from 2012, it was located at North Unit, 3rd Floor, 6th building, Shaxia Industrial Park, Minzhi Boulevard, Longhua NewDistrict, Shenzhen City, Guangdong Province, China, and The Right Side, 3rd Floor, 4th Building, Shaxia Industrial Park, Minzhi Boulevard, Longhua NewDistrict, Shenzhen City, Guangdong Province, China, The business license registration number is 91440300055103138H. The real estate was not owned bythe audited factory. The premise total land area is 820 Sq. Meters. [Structure of facility]: Factory occupied one storey as office, the other storey as production and warehouse. The main products covered the LED Lightings and LED Automotive Lamps. The presented operation only includes SMT, reflow welding, assembly, inspectionand packing. No external service subcontract is used by the factory. [Employee analysis]: 29 workers were in the factory during this audit, 10 male workers and 19 female workers, and there were 29 migrant workers from other provinces such asHunan, Guangxi, Shichuan in China. [Summary of interview]: Seven workers were interviewed on site, including 5 females and 2 males. [Summary of working hour]: Attendance records from Oct, 2015 to the audit day were provided for reviewing during this audit, the maximum overtimes were 18 hours per week and 82hours per month. NC was raised during the date of audit. [Summary of Compensation]: The salary was meeting the local government minimum wage RMB 2030.00 Per-month. OT Salary was paid according to legal requirement. The stable incomewas higher than BNW calculated by audit team. [Special scene during on site observed]: The security guard service was provided by industrial management office.The company’s business license only includes one address which was at the North Unit, 3rd Floor, 6th building, Shaxia Industrial Park, Minzhi Boulevard,Longhua New District, Shenzhen City, Guangdong Province, China. However, factory has rented another address which was at The Right Side, 3rd Floor, 4thBuilding, Shaxia Industrial Park, Minzhi Boulevard, Longhua New District, Shenzhen City, Guangdong Province, China since July 2016, the lease contract wasavailable.

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Producer : Shenzhen Zhaoyang ElectronicTechnology Co.,Ltd.

DBID : 364261 and Audit Id : 70004 Audit Date : 18/11/2016

Audit Type : Full Audit

Page 4/12

Ratings Summary

Auditee's background information

Auditee's name : Shenzhen Zhaoyang ElectronicTechnology Co.,Ltd.

Legal status : Limited Company

Local Name : 深圳市照洋深圳市照洋电电子科技有限公司子科技有限公司 Year in which the auditee was founded : 2012

Address : North Unit, 3rd Floor, 6th building, ShaxiaIndustrial Park, Minzhi Boulevard, LonghuaNew District

Contact person (please select) : Rong XU

Province : Guangdong Contact's Email : [email protected]

City : Shenzhen City Auditee’s official language(s) for writtencommunications :

Mandrain

Region : North East Asia Other relevant languages for the auditee :

English

Country : China Website of auditee (if applicable) : None

GPS coordinates : None Total turnover (in Euros) : 1278295.60

Sector : Non-Food Of which exports % : 100.00

Industry : Mechanical and electrical engineering Of which domestic market % : 0.00

If other, please specify : Production volume : 70000 pcs / month

Product Group : Transport and automotive Production cost calculation : Yes

If other, please specify : Lost time injury calculation cost : No

Product Type : LED Lightings and LED Automotive Lamps

Auditee's employment structure at the time of the audit

Total number of workers : 29 Total number of workers in the production unit to be monitored (if applicable) : 0

MALE WORKERS FEMALE WORKERS

Permanent workers 10 19

Temporary workers 0 0

In management positions 4 5

Apprentices 0 0

On probation 0 0

With disabilities 0 0

Migrants (national citizens) 10 19

Migrants (foreign citizens) 0 0

Workers on the permanent payroll 10 19

Production based workers 0 0

With shifts at night 0 0

Unionised 0 0

Pregnant - 0

On maternity leave - 0

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Producer : Shenzhen Zhaoyang ElectronicTechnology Co.,Ltd.

DBID : 364261 and Audit Id : 70004 Audit Date : 18/11/2016

Audit Type : Full Audit

Page 5/12

Finding Report

Performance Area 1 : Social Management System and Cascade Effect

Full Audit [Audit Id - 70004] Audit Date: 18/11/2016 PA Score: B Deadline date:30/03/2016

GOOD PRACTICES:None

AREAS OF IMPROVEMENT:The overall observation shows that the auditee fulfill Partially the BSCI requirement of this performance area. A senior management staff hadappointed as the management representative of SC. The auditee had identified its significant business partiners. However, gaps have been identifiedin implementation.总体观察显示工厂在该执行领域部分符合BSCI的要求。一名高级管理人员已经被任命为社会责任管理者代表。被审核方已经识别它的重要商业伙伴。但是在执行的过程当中还是存在以下差距:

1.4 - Factory has planned the capacity, however, it was not reasonalbe and cause monthly over time was exceeded to 36 hours. No meet BSCIrequirement.工厂的产能计划不合理,导致月加班超过36小时。

Remarks from Auditee:None

Performance Area 2 : Workers Involvement and Protection

Full Audit [Audit Id - 70004] Audit Date: 18/11/2016 PA Score: C Deadline date:30/03/2016

GOOD PRACTICES:None

AREAS OF IMPROVEMENT:The overall observation shows that the auditee fulfill Partially the BSCI requirement of this performance area. The management representative of SChad been appointed.The company had established BSCI management manual and related procedures; an effective grievance mechanism had beenestablished for workers. The interviewed workers knew their rights and reponsibilities. However, gaps have been identified in implementation.总体观察显示工厂在该执行领域部分符合BSCI的要求。公司已经建立BSCI管理手册和相关程序;为员工建立了有效的申诉机制。被访谈的员工了解他们的权利和责任。但是在执行的过程当中还是存在以下差距:

2.1 - Two worker representatives were voted by employees, however, the worker representatives were not awareness of BSCI code of conduct; one ofworker representative was undertaking the production supervisor, he was not belong to the non-tmanagement employee. No meet BSCI requirement.工厂有二名员工代表,但员工代表不了解BSCI 行为守则的基本内容;其中一名员工代表的职位是生产主管,不属于非管理层员工。

2.4 - The individual interviewed workers were not awareness of BSCI Code of Conduct, although the factory showed the training record included to BSCIknowladge. No meet BSCI requirement.被访谈的个别员工不了解BSCI行为守则的基本内容,虽然工厂提供的培训记录包括了BSCI行为守则的要求。

2.5 - Although the auditee has a grievance policy, no records of the cases presented are kept. All open door grievances are handled verbally, and it wasnot possible to verify whether the procedures set out for open door policy is implemented due to this lack of records. No meet BSCI requirement.尽管工厂建立了投诉政策,但是并没有保存投诉记录。所有的投诉都是口头处理的,由于缺乏记录没有办法验证投诉程序是否有效实施。

Remarks from Auditee:None

Performance Area 3 : The rights of Freedom of Association and Collective Bargaining

Full Audit [Audit Id - 70004] Audit Date: 18/11/2016 PA Score: A Deadline date:

GOOD PRACTICES:None

AREAS OF IMPROVEMENT:The overall observation shows that the auditee fulfills the requirement of this performance area. The overall observation shows that the auditee fulfillsthe requirement of this performance area. It was noted that the factory had established policies to guarantee the rights of freedom of association andcollective bargaining. Per the workers' and worker representative's statement, they were not limited or other unfair treatment by the factory onforming, joining and voting for a legal worker organization and collective bargaining. Currently, no collective bargaining existed in the factory.总体观察工厂符合该执行领域的要求。工厂建立起了政策去保证自由结社和集体谈判的权利。根据员工和员工代表的陈述,工厂对于员工成立、参加和投票一个合法工人组织和集体谈判没有任何限制和其他的不公平对待。访谈显示员工与员工代表之间的沟通并无受限。当前厂内没有进行集体谈判事项。

Remarks from Auditee:

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Producer : Shenzhen Zhaoyang ElectronicTechnology Co.,Ltd.

DBID : 364261 and Audit Id : 70004 Audit Date : 18/11/2016

Audit Type : Full Audit

Page 6/12

Performance Area 4 : No Discrimination

Full Audit [Audit Id - 70004] Audit Date: 18/11/2016 PA Score: A Deadline date:

GOOD PRACTICES:None

AREAS OF IMPROVEMENT:The overall observation shows that the auditee fulfills the BSCI requirement of this performance area. The company had established BSCImanagement manual and nodiscrimination procedure had been established, the interviewed workers knew their rights and reponsibilities.总体观察显示工厂在该执行领域符合BSCI的要求。公司已经建立BSCI管理手册和无歧视程序,被访谈的员工了解他们的权利和责任。

Remarks from Auditee:

Performance Area 5 : Fair Remuneration

Full Audit [Audit Id - 70004] Audit Date: 18/11/2016 PA Score: A Deadline date:

GOOD PRACTICES:Auditee has a calculation method which is fair remuneration scan, the calculation result showed that the employee's stable income was more than local lowestwage and BNW(Basic Need Wage).

AREAS OF IMPROVEMENT:The overall observation shows that the auditee fulfills the requirement of this performance area. The company has established remunerationmanagement procedure, the wages are paid in a timely manner; regularly and fully in legal tender, employees was paid the sufficient remunerationcould meet a decent living standard.总体观察显示工厂在该执行领域符合BSCI的要求。公司建立了工资报酬管理程序, 并按固定的形式、周期和货币支付员工工资,员工可以获得较为体面的收入。

Remarks from Auditee:

Performance Area 6 : Decent Working Hours

Full Audit [Audit Id - 70004] Audit Date: 18/11/2016 PA Score: D Deadline date:30/03/2016

GOOD PRACTICES:None

AREAS OF IMPROVEMENT:The overall observation shows that the auditee fulfill Partially the BSCI requirement of this performance area. Company has established workinghours management procedure. However, gaps have been identified in implementation.总体观察显示工厂在该执行领域部分符合BSCI的要求。公司建立了工作时间管理制度,但是在执行的过程当中还是存在以下差距:

6.2 - Through documents review and workers interview, it was noted that From Nov-2015 to Oct-2016, the monthly overtime hours of 5 out of 5 randomlysampled employees exceeded to 36 hours, the monthly maximum was up to 82 housr. (BSCI Questionnaire 6.2). No meet the requirements of ChinaLabour Law.通过文件审核和工人访谈,5名抽样的工人中的6名工人从2015年11月至2016年10月的月加班时间超过36小时,最多达到82小时,不符合劳动法的要求。

Remarks from Auditee:None

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Producer : Shenzhen Zhaoyang ElectronicTechnology Co.,Ltd.

DBID : 364261 and Audit Id : 70004 Audit Date : 18/11/2016

Audit Type : Full Audit

Page 7/12

Performance Area 7 : Occupational Health and Safety

Full Audit [Audit Id - 70004] Audit Date: 18/11/2016 PA Score: B Deadline date:30/03/2016

GOOD PRACTICES:None

AREAS OF IMPROVEMENT:The overall observation shows that the auditee fulfill Partially the BSCI requirement of this performance area. The company had established BSCImanagement manual and related procedures; an effective Occupational Health and Safety mechanism had been established for workers. Theinterviewed workers knew their rights and reponsibilities, and all the relative risks in the premises. However, gaps have been identified inimplementation.总体观察显示工厂在该执行领域部分符合BSCI的要求。公司已经建立BSCI管理手册和相关程序;为员工建立了有效的职业健康安全机制。被访谈的员工了解他们的权利和责任,以及场所内部的各种风险。但是在执行的过程当中还是存在以下差距:

7.1 - Through worker and worker representative interivew, it was noted that worker representative did not involve into the process of health and safetyregulation establish. No meet BSCI requirement.员工和员工代表访谈得知,他们没有参与健康安全管理制度的制定过程。

7.3 - Factory didn't take the Occupational Hazards Aspects Inspection for working environment. No meet requirement of Occupational Disease PreventionLaw of the People Republic China.工厂没有检测车间的职业危害因素。

7.4 - Factory has taken hazards identification and risk evaluation properly, however, workers and their representatives were not consulted during hazardsidentification and risk evaluation of OHS systems. No meet BSCI requirement.基于现场文件评审及工人访谈得知,工厂已进行了危险源识别及风险评价,但工人及他们的员工代表没有参与职业健康安全体系的危险源识别及评价过程。

7.8 - Factory didn't post the Preparedness and Response Procedure. No meet BSCI requirement.工厂没有张贴应急准备及响应程序。

7.13 - One switch box was not installed the inner protection board in the office area. No meet BSCI requirement. 办公区域的一个配电箱没有安装内部防护挡板。

7.16 - Factory post escape and evacuation plan at the workshop and office area. However, the color and size was not mee the National Standardrequirement.(GB/T 25894-2010).工厂在车间及办公区域都张贴了疏散图,但是疏散图的颜色及尺寸不符合国标要求。

7.19 - Factory didn't sign a first aid agreement with any medical facility. No meet BSCI requirement.工厂没有与任何医疗机构签订急救协议。

7.22 - Factory did not provide the liquid soap and toilet paper in Office lavatory. No meet BSCI requirement.工厂没有给办公区域的洗手间配备洗手间和厕纸。

7.23 - No need to provide transportation because 70% employees were living nearly factory.大部分员工都住在工厂附近,工厂不需要提供班车服务。

Remarks from Auditee:None

Performance Area 8 : No Child Labour

Full Audit [Audit Id - 70004] Audit Date: 18/11/2016 PA Score: A Deadline date:

GOOD PRACTICES:None

AREAS OF IMPROVEMENT:The overall observation shows that the auditee fulfills the requirement of this performance area. It was noted that the factory had established policiesand procedure to prevent recruitment of child labor. The age verification procedure was used during hiring process and periodic check wasconducted to indentify suspicious child labor. A child labor remedition procedure was also established to handle child labor issue.总体观察显示工厂符合了该执行领域的要求。工厂建立政策和程序去防止雇佣到童工。在招聘中会使用到年龄核实程序并且会定期检查确认可疑童工身份。工厂同时建立了童工补救措施去处理童工问题。

Remarks from Auditee:

Performance Area 9 : Special protection for young workers

Full Audit [Audit Id - 70004] Audit Date: 18/11/2016 PA Score: A Deadline date:

GOOD PRACTICES:None

AREAS OF IMPROVEMENT:The overall observation shows that the auditee fulfills the requirement of this performance area. It was noted that the factory had established policiesand procedure to identify young workers. A procedure regarding working conditions of young workers was also established to handle young workerissue and minimize the risks. Currently no young worker was hired.总体观察显示工厂符合了该执行领域的要求。工厂建立了政策和程序去识别未成年工。一个针对未成年工工作条件的程序也建立起来去处理未成年工事项和降低风险。审核当天工厂未发现未成年工。

9.6 - No young workers were found.工厂未使用青年工人。

Remarks from Auditee:

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Producer : Shenzhen Zhaoyang ElectronicTechnology Co.,Ltd.

DBID : 364261 and Audit Id : 70004 Audit Date : 18/11/2016

Audit Type : Full Audit

Page 8/12

Performance Area 10 : No Precarious Employment

Full Audit [Audit Id - 70004] Audit Date: 18/11/2016 PA Score: A Deadline date:

GOOD PRACTICES:None

AREAS OF IMPROVEMENT:The overall observation shows that the auditee fulfills the requirement of this performance area. The factory has established a policy based on BSCIstandards and local law requirements to protect employment relationship. All hired workers signed labor contracts within one month with the auditedfactory and a copy of labor contracts was provided to workers. The contents on labor contracts were fully in compliance with local law on workinghour, payments, working condtion protection, etc. There was not evidence to show the factory tried any unfair employment method to reduce itsobligations.总体观察显示工厂符合了该执行领域的要求。工厂基于BSCI的标准和当地法规要求建立了包含雇佣关系的政策和程序。所有雇佣的员工都会与所审核的工厂在一个月内签订劳动合同并且会留一份劳动合同副本给员工。劳动合同的内容,如工时,工作,工作条件等均完全符合当地法律。没有任何证据显示工厂是同通过不公平的雇佣方式去减少其义务。

Remarks from Auditee:

Performance Area 11 : No Bonded Labour

Full Audit [Audit Id - 70004] Audit Date: 18/11/2016 PA Score: A Deadline date:

GOOD PRACTICES:None

AREAS OF IMPROVEMENT:The overall observation shows that the auditee fulfills the requirement of this performance area. The factory has established a policy based on BSCIstandards and local law requirements to identify and prevent bonded labor. Training regarding identifing and reporting bonded labor was provided toworkers periodically. There was not any form of bonded labor observed or reported during the audit.总体观察显示工厂符合了该执行领域的要求。工厂基于BSCI的标准和当地法规要求建立了识别和防止强迫劳工的政策和程序,定期给员工提供强迫劳工的识别与报告。在这次审核中没有发现或者得到报告强迫劳工的情况。

Remarks from Auditee:

Performance Area 12 : Protection of the Environment

Full Audit [Audit Id - 70004] Audit Date: 18/11/2016 PA Score: B Deadline date:30/03/2016

GOOD PRACTICES:None

AREAS OF IMPROVEMENT:The overall observation shows that the auditee fulfill Partially the BSCI requirement of this performance area. Company carried out environmentprotection and management based legal requirements. However, gaps have been identified in implementation.总体观察显示工厂在该执行领域部分符合BSCI的要求。公司基本按照法规要求进行环境管理,但是在执行的过程当中还是存在以下差距:

12.1 - Factory didn't identify and evaluate the environmental aspects. No meet BSCI requirement.工厂没有进行环境因素识别及评价。

Remarks from Auditee:None

Performance Area 13 : Ethical Business Behaviour

Full Audit [Audit Id - 70004] Audit Date: 18/11/2016 PA Score: B Deadline date:30/03/2016

GOOD PRACTICES:None

AREAS OF IMPROVEMENT:The overall observation shows that the auditee fulfills Partially the BSCI requirement of this performance area. The company had established BSCImanagement manual and related procedures. However, gaps have been identified in implementation.总体观察显示工厂在该执行领域部分符合BSCI的要求。公司已经建立BSCI管理手册和相关程序。但是在执行的过程当中还是存在以下差距:

13.4 - The factory did not establish personal private information confidential policy, such as personal profile, health examination and other disciplinarymeasures etc. No meet BSCI requirement.工厂没有建立个人隐私信息保密政策,例如:个人档案、健康体检及纪律处罚措施等的管理。

Remarks from Auditee:None

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Producer : Shenzhen Zhaoyang ElectronicTechnology Co.,Ltd.

DBID : 364261 and Audit Id : 70004 Audit Date : 18/11/2016

Audit Type : Full Audit

Page 9/12

Summary

Audit Type Date Audit Id PA1 PA2 PA3 PA4 PA5 PA6 PA7 PA8 PA9 PA10 PA11 PA12 PA13 Overall Rating

Full Audit 18/11/2016 70004 B C A A A D B A A A A B B C

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Producer : Shenzhen Zhaoyang ElectronicTechnology Co.,Ltd.

DBID : 364261 and Audit Id : 70004 Audit Date : 18/11/2016

Audit Type : Full Audit

Page 10/12

Producer Photos

Photo of the code of conduct on displayCOC Display.JPG

Photo of the inside of the main production hallSuggestion Box.JPG

Photo of fire safety equipmentEmergency Light.JPG

External photo(s) of the production unit(s)Facotry Entrance.JPG

Photo of the inside of the main production hallWarehouse.JPG

Photo of fire safety equipmentFire Extinguishers.JPG

External photo(s) of the production unit(s)House number.JPG

Photo of the inside of the main production hallWorkshop.JPG

Photo of fire safety equipmentFire Hydrant.JPG

Photo of the inside of the main production hallAttendance Record Machine.JPG

Photo first aid facilitiesFirst Aid Box.JPG

Photo of the sanitary facilitiesLavatory.JPG

Photo of the inside of the main production hallOffice Area.JPG

Photo first aid facilitiesFirst Aider Certificates.JPG

Photo of the sanitary facilitiesPotable Water Facility.JPG

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Producer : Shenzhen Zhaoyang ElectronicTechnology Co.,Ltd.

DBID : 364261 and Audit Id : 70004 Audit Date : 18/11/2016

Audit Type : Full Audit

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Photo of the inside of the main production hallOffice Reception.JPG

Photo of fire safety equipmentEmergency Light Testing.JPG

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Producer : Shenzhen Zhaoyang ElectronicTechnology Co.,Ltd.

DBID : 364261 and Audit Id : 70004 Audit Date : 18/11/2016

Audit Type : Full Audit

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