alliance for water stewardship Conformity assessment report · intention to pursue AWS...

Alliance for Water Stewardship Comformity Assessment Report

Prepared for Career Electronic (Kunshan) Co., Ltd.

(AWS-010-INT-CAB-00-08-00015-0076)

Prepared by: SGS

SGS Ref.: CN/SZH

Version: 1

Date: Dec. 14, 2018

This is a controlled document, which is subject to SGS document control procedures.

It may not be reproduced in whole or in part without the express permission of SGS China

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REPORT DETAILS

REFERENCE

CLIENT REFERENCE Wang Changzhen

REPORT TITLE ALLIANCE FOR WATER STEWARDSHIP CONFORMITY ASSESSMENT REPORT

DATE SUBMITTED: Dec. 14, 2018

CLIENT: Changzhen Wang

Facility Manager, Career Electronic (Kunshan) Co., Ltd.

T +86 0512 5771 8998 Ext. 589

No. 18, Chin Sha Chiang South Road, Kunshan Development Zone, Kunshan City, Jiangsu Province P.R.China http://www.Career.com.cn/

[email protected]

PREPARED BY: Andy ZHOU Jiansong Chang

SGS-CSTC Standards Technical Services Co., Ltd. Suzhou Branch

4st floor, D Building, Ascendas Industry Park, No.5 Xinghan Street, SIP Suzhou, P. R. China. 215021

Tel: +86 (0) 512 6299 0222

E-mail: [email protected]

SIGNED: Andy ZHOU Signed:

TECHNICAL SIGNATORY

Francesca Cerchia Signed:

STATUS FINAL DRAFT

NOTICE This document is issued by SGS under its General Conditions of Service accessible at http://www.sgs.com/terms_and_conditions.htm. Attention is drawn to the limitation of liability, indemnification and jurisdiction issues defined therein.

Any holder of this document is advised that information contained hereon reflects SGS’s findings at the time of its intervention only and within the limits of Client’s instructions, if any. SGS’s sole responsibility is to its Client and this document does not exonerate parties to a transaction from exercising all their rights and obligations under the transaction documents. Any unauthorised alteration, forgery or falsification of the content or appearance of this document is unlawful and offenders may be prosecuted to the fullest extent of the law.

http://www.flexium.com.cn/

http://www.flexium.com.cn/

mailto:[email protected]

http://www.sgs.com/terms_and_conditions.htm

December 14, 2018 [ALLIANCE FOR WATER STEWARDSHIP CONFORMITY ASSESSMENT REPORT]

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TABLE OF CONTENT

REPORT DETAILS ................................................................................................................ 2

1 EXECUTIVE SUMMARY ................................................................................................. 4

2 SCOPE OF ASSESSMENT ............................................................................................ 5

3 STAKEHOLDER ANNOUNCEMENT AND CONSULTATION ........................................ 8

4 DESCRIPTION OF CATCHMENT ................................................................................. 11

5 SUMMARY OF SHARED WATER CHALLENGES ....................................................... 18

6 INDICATORS CHECKLIST ........................................................................................... 19

7 AUDIT FINDINGS ......................................................................................................... 28

8 SUMMARY .................................................................................................................... 31

9 OPPORTUNITIES FOR IMPROVEMENT...................................................................... 32

10 CONCLUSIONS AND RECOMMANDATIONS ............................................................. 33

11 REFERENCES .............................................................................................................. 34

APPENDIX 1 SGS AUDIT CHECKLIST............................................................................... 37

APPENDIX 2 CAREER ACTION PLANS RESPONSE TO FINDINGS ................................ 38


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1 EXECUTIVE SUMMARY

The scope of services covers the conformity assessment of water use in compliance with the

AWS International Water Stewardship Standard (Version 1.0) for Career Electronic

(Kunshan) Co., Ltd. (hereinafter referred to as “Career” or “the site”) located at No. 18, Chin

Sha Chiang South Road, Kunshan Development Zone, Kunshan City, Jiangsu Province

P.R.China. The assessment has been completed in compliance with the AWS Certification

requirements, Version 1.0 dated July 2015.

Career started operating in 1998, and it manufactures and assembles flexible printed circuit

boards.

On Nov. 14-15, 2018, SGS-CSTC Standards Technical Services Co., Ltd. (hereinafter

referred to as “SGS”) conducted the conformity assessment for Career’s facilities and

activities with regard to certification to the AWS Standard. A total of five findings were raised

during the course of the audit process, and they were all categorized as minor non-

conformities.

Career responded the findings raised with root cause analysis and action plans, and

submitted corrected documentation as evidence to successfully closeall findings raised in the

audit.

Given the review of evidence provided and the site visit, SGS recommends that Career be

awarded AWS Core Certified status with a surveillance audit interval of annual frequency.


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2 SCOPE OF ASSESSMENT

The scope of services covers the conformity assessment of water use in compliance with the

AWS International Water Stewardship Standard (Version 1.0) for Career Electronic

(Kunshan) Co., Ltd. (hereinafter referred to as “Career”) located at No. 18, Chin Sha Chiang

South Road, Kunshan Development Zone, Kunshan City, Jiangsu Province P.R.China. The

assessment has been completed in compliance with the AWS Certification requirements,

Version 1.0 dated July 2015.

A pre-assessment for Career’s facilities and activities with regard to certification to the AWS

Standard was performed by SGS-CSTC Standards Technical Services Co., Ltd. (hereinafter

referred to as “SGS”) on Sep. 25-26, 2018. During the pre-assessment, SGS carried out an

on-site audit covering water supply facilities, electroplating workshop, chemical warehouse,

hazardous waste storage, wastewater treatment facilities, online monitoring devices installed

for treated effluent, employees’ canteen and dormitories, personnel interviews and document

reviews. A total of twelve findings were raised during the course of the pre-assessment

process. Career responded that corrective actions will be taken to successfully close all

findings raised in the pre-assessment before the commencement of conformity assessment.

On Nov. 14-15, 2018, SGS conducted the conformity assessment of Career’s facilities and

activities with regard to certification to the AWS Standard. Table 2.1 presents SGS audit

team. The audit plan is attached as a separate document.

Table 2.1 SGS Audit Team

Audit Team Qualifications/Experience

Andy ZHOU Team Leader

AWS certified auditor, with more than 12 years experience

in pollution control, environmental impact assessment,

ISO14001 audit and training.

Jiansong Chang Team Member

AWS certified auditor, with more than 23 years experience

in environmental impact assessment (EIA), treatment of

wastewater, solid waste and hazardous waste, more than 5

years experience in performing environmental and social

risk assessment in line with the IFC E&S, FSC FM and

RTRS soy bean production standards.

Donglin Zhu Technical Expert

Dr. Donglin Zhu, senior engineer, WWF’s special advisor of

water stewardship, and external tutor of graduate student

of Environmental College, Fudan University. A key expert

to develop the state master plan for controlling Tai Lake

contamination, and to be responsible for the study of 13th


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Five-Year Plan for water environmental governance of Tai

Lake catchment.

During the conformity assessment, the audit team spent 0.5 day on the stakeholder

consultation meeting, and 1.5 day on the inspection of Career’s installations and activities in

its workshops, together with personnel interviews and document reviews.

Career provided most of the requested supporting documentation as evidence whilst on site.

SGS provided initial feedback on the gaps between Career’s current management and the

level required by the standard during the closing meeting of the conformity assessment on

Nov. 15, 2018.

Table 2.2 shows some representative pictures regarding the site assessment.

Table 2.2 Photos from Career Site Assessment

Rain water discharge

Online monitoring devices installed for treated

effluent

Domestic sewage discharge

Treated effluent discharge


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Waste water treatment pool

Chemical warehouse

Kuilei Lake (one of Kunshan’s drinking water sources)

Internal Training for Employees Regarding Water

Stewardship


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3 STAKEHOLDER ANNOUNCEMENT AND CONSULTATION

Following the AWS Certification Requirements, before the on-site conformity assessment,

SGS prepared a stakeholder announcement on Oct. 15, 2018, which stated Career’s

intention to pursue AWS certification. Besides submitting to AWS for publication on the AWS

website, the stakeholder announcement was also posted on the information disclosure

bulletin board respectively installed at Career’s canteen, outside of Career’s main gate and

surrounding community and displayed on Career’s website:

http://www.careergroups.com/ZH/csr/Default.aspx?Id=46

SGS received no feedback information since the release of the stakeholder announcement.

Photo 3.1 Information Disclosure Bulletin

Board Installed at Career’s Cateen

Photo 3.2 Information Disclosure Bulletin Board

Installed Outside of Career’s Main Gate

Photo 3.3 Information Disclosure Bulletin Board

Installed at Pingxiang Community



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During the conformity assessment, we also held a stakeholder consultation meeting. Table

3.1 presents the personnel interviewed.

Table 3.1 Personnel Interviewed during Stakeholder Consultation Meeting

Organization Personnel Interviewed

Surrounding community Mr. Xu, director of Pingxiang Community

Employees' representative

Ms. Ruan, chairman of trade union

Ms. Jun Duan, employee and also an elected

representative of rural migrant workers in Kunshan

City

Supplier

Mr. Jun Zhou, HSE manager of YASEN

Mr. Baodong Cheng and Mr. Jizhang Li, HSE

managers of SONGYANG

Neighbouring factory Mr. Tang, general manager of YUANDENG

Mr. XIN, director of SANTAI

AWS

Ms. Zhenzhen Xu, chief representative of Greater

China

Ms. Chang Ge, official of Greater China

Apple

Ms. Emily Chen, manager of water stewardship

Mr. Jack Yao, officer of water stewardship

The stakeholder consulting meeting was held in a Career’s conference room in the morning

of 14 November 2018. All participants gave a high appraisal to Career’s efforts for its water

stewardship. According to Mr. Xu, director of Pingxiang Community, the quality of local water

bodies has been improved a lot since the implementation of more stringent regulations on

water pollution control. Managers from Career’s suppliers and neighbouring factories showed

their willingness to cooperate with Career to strengthen water stewardship, especially by

sharing water-saving technologies. As an elected representative of rural migrant workers in

Kunshan City, Ms. Jun Duan expressed a strong sense of water conservation. She often

educates her colleagues and children that if no actions are taken to save water, the last drop

of water on the earth may be the human’s tears. Ms. Ruan, chairman of Career’s trade union

mentioned that a series of measures have been taken by Career to improve employees’

sanitation and health conditions including the establishment of a dormitory committee, a

canteen committee, a factory manager’s open day and the trade union’s suggestion box.


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According to Ms. Ruan, employees’ suggestions mainly focused on the canteen and relevant

improvement measures had been taken by the canteen.

In addition, the interview with 2 employees during the site visit further showed their

satisfaction with Career’s WASH conditions.

Photo 3.4 and 3.5 show the stakeholder consultation meeting.

Photo 3.4 SGS Auditor Introducing the

Requirements of AWS Standard

Photo 3.5 Stakeholders Participating in the

Consultation Meeting


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4 DESCRIPTION OF CATCHMENT

Both Career’s domestic and production water comes from the municipal water supplied by

Kunshan Waterworks Group, which has three water supply plants and two water sources

including the Kuilei Lake and the Yangtze River. According to the public information of

Kunshan Waterworks Group, its water supply covers the whole Kunshan city with the total

area of 927km2, and the daily maximum water supply is 1,102,100m3. In addition, according

to Kunshan municipal plan, the control target of water consumption in 2020 will be

7.85x108m3. Since the total water consumption of Kunshan in 2017 is 4.3128x108m3, no

water scarcity will happen in Kunshan in the next two years.

Career’s domestic sewage is discharged into the municipal pipeline network, and its

industrial wastewater is discharged into the local electroplating centre, then into the

wastewater treatment plant of Guangda Water Affairs (or named Kunshan Gangdong

Wastewater Treatment Plant). The treated effluent is discharged into the Taicangtang River,

and finally flows into the Wusongjiang River. Career has built the following wastewater

treatment facilities at the site:

1 set of pre-treatment system for highly concentrated alkali wastewater with its treatment

capacity of 90 m3/d;

1 set of pre-treatment system for highly concentrated acid wastewater with its treatment


1 set of pre-treatment system for cyanide-containing wastewater with its treatment


1 set of pre-treatment system for nickel-containing wastewater with its treatment capacity

of 80 m3/d;

1 set of integrated wastewater treatment system with its treatment capacity of 1,000

m3/d; and

1 set of reclaimed water/gray water reuse system with its treatment capacity of 700 m3/d.

Based on the location of the water source and final destination of effluent, the external

boundary for the sustainable water stewardship of the factory is determined as the

Wusongjiang River Catchment in Kunshan City.

The Wusongjiang River catchment belongs to a sub-catchment of the Taihu Lake

Catchment. The Wusongjiang River originates from the Taihu Lake. It flows through Wujiang,

Suzhou, Kunshan and Shanghai's Qingpu, Jiading, Minhang, Putuo, Changning, Jing'an,

Hongkou and Huangpu districts, and then enters into the Huangpu River at the Waibaidu

Bridge. With the Bei Xinjing as the boundary, the upper reaches of the Wusongjiang River


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are called Wusongjiang River by local people, and the lower reaches of the Wusongjiang

River is located in the east of the Bei Xinjing. After entering into the Shanghai area, it is

called the Suzhou River by Shanghainese. It is 125 km long, including 53.1 km long in the

territory of Shanghai. Wusongjiang River is 40km long from west to east in Kunshan. It enters

into Kunshan from Suzhou Industrial Park (where the Jianglizhuang monitoring section

controlled by Jiangsu province is installed) and flows into Shanghai (where the Shipu

monitoring section controlled by the state is installed) after passing through Kunshan. With

the total land area of 735.6 km2, and the total water area of 43.5 km2, the Wusongjiang

River catchment covers Bacheng Town, Zhoushi Town, High-tech Zone, Development Zone,

Lujia Town, Huaqiao Town, Zhangpu Town and Qiandeng Town. There are 1,917 rivers and

8 provincial key lakes in the catchment.

Figure 4.1, 4.2 and 4.3 respectively show the catchment of the Tai Lake, the catchment of

Wusongjiang River, and the water system in the catchment of Wusongjiang River.

Figure 4.1 The Catchment of Tai Lake

Tai Lake

Yangtze River

Shanghai Suzhou

Wusongjiang River

Catchment


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Figure 4.2 The Catchment of Wusongjiang River

Career


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Figure 4.3 The Water System in the Catchment of Wusongjiang River

In addition, to protect drinking water sources and ecological environment, Kunshan has

demarcated the drinking water protected areas and the ecological protection red lines. Figure

4.4 and 4.5 respectively present the conservation areas of drinking water and the map of

ecological conservation red lines.

Yangcheng Lake

Kuilei Lake

Loujiang River

Qingyanggang River

Wusongjiang River

Wusongjiang River

Kunshan

Suzhou Industrial

Park

Shanghai Qingpu District

Shanghai Jiading District

Career


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Figure 4.4 Kunshan Conservation Areas of Drinking Water

Yangcheng Lake

Kuilei Lake

Legend:

First-grade protection zone

Second-grade protection zone

Prospective protection zone

Water intake

Miaojinghe Water Supply Plant


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Figure 4.5 Distribution Map of Kunshan Ecological Conservation Red Lines

Legend:

Red: First-grade control area

Green: Second-grade control area

Yangcheng

Lake

Kuilei

Lake

Wetland of

Dianshan Lake

Drinking Water

Conservation Area

Conservation Area for Chinese Mitten Crab

Conservation Area

for Culter Ablurnus

Bailewsky

Miaojinghe

Drinking Water

Conservation Area


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Figure 4.6 shows Career’s water supply and wastewater discharge.

Figure 4.6 Career’s Water Supply and Wastewater Discharge (Blue: Water Supply; Orange: Wastewater)

Kuilei

Lake

Water Supply Plant of

Kunshan Development Zone

Kunshan

Gangdong

Wastewater

Treatment Plant

Career

Electroplating

Center

Taicangtang

River


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5 SUMMARY OF SHARED WATER CHALLENGES

Career has identified general shared challenges in the catchment and these are listed in Table 5.1.

Table 5.1.Detailed Shared Water Challenges for Career

No. Water Challenge Associated Government Authority initiative/Plan*

Relevant/Rationale for Stakeholders

Relevant/Rationale for Site Priority (1-4)

Rationale for Prioritization

Countermeasure/Plan

1 More difficult to obtain water license

Prohibition of expension project construction

Local residents are given priority to water use. More difficult for an enterprise to get water license for its expension project.

Difficulty for Career in expansion

1 Based on Concerns and potential influence on normal production: 1: Small 2: Medium 3: High

Transferring the order for goods to other production site

2 More stringent requirements for water efficiency and wastewater discharge

Requirement of higher water recycling and higher quality of wastewater discharge

Residents will be less affected by water pollution. An enterprise will invest more money to increase its water recycling.

The increase of water recycling may result in Career’s increase of non-compliance risk

1 Expansion of water recycling system and establishment of buffer pool for effluent

3 Policy uncertainty (such as some emergency notifications)

No effective solutions are found at the moment and only some specified emergency requirements are advanced.

Non-compliance and penalty may occur for an enterprise if it fails to receive the notification in time.

Career may fail to inform top management the reason of restriction for discharge in an effective and timely manner.

2 Actively communicate with policy-making department

4 Groundwater and surface water contamination risk

Control of soil and water contanmination and introduce relevant control parameters

Local residents may complain with an enterprise if they discover soil and water pollution.

Invest more money to improve its infrastructure

2 Taking anti-leakage measures

5 Insufficient water treatment infrastructure (such as collection of rainwater and wastewater, and centralized treatment of wastewater)

New sewage treatment facilities may be built to collect and treat domestic sewage

Increase the safety risks of local communities’ drinking water

Insufficient drainage during the rain storms may result in water pollution

3 Emergency gathering tank at the site

6 Potentially increased levels of water shortage

Control of water use during peak period. Restriction of new and expansion projects.

Influence of an enterprise’ normal production which may result in the relocation

Increase the stress of water use

3 Increasing the efficiency of water use

7 Inadequate legal and regulatory supervision

Enhance all kinds of supervisions including test by a third party.

Non-compliance may be not found and corrected in a timely manner.

Non-compliance may be not found and corrected in a timely manner.

3 Managing its activities according to relevant environmental regulations

* Associated Government Authorities including national and local People’s Governments, national and local environmental protection departments, national and local water affairs departments, etc.


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6 INDICATORS CHECKLIST

As per the requirement set out in the Section 2.11.3.1 of the AWS Certification Requirements, Table 6.1 presents all the CORE AWS indicators

with the relevant reviewed evidence provided by Career.

Table 6.1 Evidence Reviewed by SGS Against Each CORE AWS Indicator

Indicator Details (Core) Evidence Reviewed/Document Reference

1 Leadership (core)

1.1 Leadership commitment on water stewardship Mr. Jinlong Qiu, Career’s vice general manager has signed the “Water Stewardship Commitment” developed for Career in Kunshan, which are made public on Career Group’s website. Please refer to the following website:


REF001: Water Stewardship Commitment

1.1.1 Has the organisation signed and published a statement related to his water stewardship commitment that includes all of the elements listed in core criteria 1.1?

A water stewardship commitment to follow all the AWS core criteria has been signed by Mr. Jinlong Qiu, Career’s vice general manager. This commitment has been displayed on the website of Career Group:


and posted on the bulletin board respectively installed at Career Kunshan factory, and nearby community (Donggao Community).

REF002: Bulletin board installed at employees’ canteen of Career

REF003: Bulletin board Installed outside of factory main gate of Career

REF004: Bulletin board installed at Donggao Community

1.2.1 Has the organisation elaborated, agreed upon and discloses a water stewardship policy?

A water stewardship policy has been made public on Career Group’s website:


and posted on the bulletin board respectively installed at Career Kunshan factory, and nearby community (Donggao Community).





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REF005: Water Stewardship Policy

2 Water challenges (core)

2.1.1 Site boundaries (map) REF006: Layout of Career Factory

2.1.2 Name and location of sources of water (immediate and ultimate) REF007: Map of Water Supply and Wastewater Discharge

2.1.3 Name and location of effluent discharges REF007: Map of Water Supply and Wastewater Discharge

REF008: Map of Water System in the Catchment of Wusongjiang River

2.1.4 Description or map of catchment (s) REF009: Catchment of Tai Lake

REF010: Catchment of Wusongjiang River

2.2.1 Identification of stakeholders and their water challenges (list of stakeholders, prior engagement and their water challenges)

REF011: List of Stakeholders

2.2.2 Site sphere of influence (how the stakeholders are within the sphere of influence).

REF012: EIA Report developed for Career’s construction project in July 2018 (page 34-35)

2.3.1 Catchment data (catchment plan, public initiatives and/or public goals for the site)

REF013: List of Catchment Plans, Scenarios and Notifications updated in 2018

REF014: Response to Finding 01MINCAR

2.3.2 Water governance for the catchment: Water legal and regulatory requirements, including water and water use rights

REF015: List of national and local applicable laws, regulations and standards related to water and water use rights updated in 2018

2.3.3 Water balance for the catchment (surface water, ground water, other)

REF016: Career Water Stewardship Report

2.3.4 Appropriate and credibly measured data to represent the physical, chemical and biological status of the site’s water source(s) by



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temporally relevant time unit, and commentary on any anticipated future changes in water quality

2.3.5 Water related areas for the catchment: identification of the areas and description of current status and trends

REF017: Conservation Plan for Ecological Red Line Areas of Jiangsu Province

REF018: Implementation Plan for Ecological Red Line Areas of Kunshan City

REF019: Distribution Map of Kunshan Ecological Conservation Red Lines

EEF020: Kunshan Conservation Areas of Drinking Water

2.3.6 Infrastructure for the catchment: available information on current and projected sufficiency of water to meet the needs of the catchment


2.4.1 Water data for the site: water stewardship and incident response plan

REF021: Career Water Stewardship Plan (EP05-F1)

REF022: Procedure for Emergency Control

REF023: Risk Assessment Report for Emergent Environmental Incidents

REF024: Emergency Response Plan for environmental emergencies registered in local environmental protection authority


2.4.2 Water data for the site: water balance (volumetric balance of water input and output)

REF026: Analysis of Water Balance in July 2018

REF027: Analysis of Water Balance in August 2018

REF028: Analysis of Water Balance in September 2018

REF029: Analysis of Water Balance in October 2018

REF030: Summary Analysis of Water Balance from Janaury to October 2018

2.4.3 Water data for the site: water quality (direct and outsourced water effluent and also possible pollution sources)

REF031: Pictures of online monitoring devices

REF032: Test report for treated effluent in August 2018


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REF033: Test report for treated effluent in September 2018

REF034: Test report for treated effluent in October 2018

2.4.4 Water data for the site: water quality (inventory of chemicals stored on site that are possible causes of water pollution)

REF035: List of chemicals

REF036: Emergency response plan for chemical leakage

2.4.5 Water data for the site: On-site identified water related. Documentation identifying existing, or historic, onsite Important Water-Related Areas, including a description of their status





2.4.6 Water data for the site: water related costs, revenues and quantification of social, environmental and economic value generated by the site to the catchment

REF037: Analysis of water-related costs

2.5.1 Indirect water use: list primary inputs with their associated (annual) water use and, if possible, the origin of the water

REF038: List of suppliers of raw materials and chemicals including their water use and related water risk

2.5.2 Indirect water use: list of outsourced services that consume or affect water quality. List estimated annual withdrawals and quality data.



2.6.1 List of shared water challenges that affect the catchment REF040: List of Shared Water Challenges in the Catchment

2.7.1 Site risks and opportunities: list of site water related risks and actions to address the challenges

REF041: Career Water-Related Risks and Opportunities

2.7.2 Site risks and opportunities: list water related opportunities REF041: Career Water-Related Risks and Opportunities

2.7.3 Site risks and opportunities: analysis of potential savings/value creation that could result from actions to address the challenges.



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Look at the actions in the context of water quality, water related areas, water governance, etc.

3 Stewardship strategy and plan (core)

3.1.1 Evidence of a system that periodically evaluates compliance with legal and regulatory requirements in criteria 2.3, together with names of those responsible.

REF015: List of national and local applicable laws, regulations and standards related to water and water use rights updated in 2018

REF042: Controlling Procedure for Laws, Regulations and Other Requirements (EP04)

REF043: Table of compliance review

3.2.1 Stewardship strategy that contains water challenges within the catchment and risks for the site together with the site responses

REF044: Career Water Stewardship Strategy

3.2.2 Stewardship plan that contains:

a) List of targets (as per criteria 2.7) and how continuous improvement and best practice are achieved. The targets need to be SMART

REF045: Procedure for the Management of Objectives and Targets (EP05)

REF046: Table for Tracking the Achievement of Objectives and Targets (EP05-F2)

REF047: Table of Objectives and Targets in 2018


b) Proposed actions to achieve the targets and names of individuals responsible for each


c) A budget for the proposed actions with a cost benefit analysis REF021: Career Water Stewardship Plan (EP05-F1)

d) Links to the desired results in terms of risks/opportunities, water stewardship outcome and shared water challenges


3.3.1 Evidence of responsiveness and resilience to water related risks embedded in the site’s incident response plan




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REF024: Emergency Response Plan for environmental emergencies registered in local environmental protection authority


3.4.1 Evidence of notification to relevant catchment authority of the intention of the site to contribute to the objectives of the catchment plan

REF048: Record of communication with local environmental protection authority via email

4 Implementation of the water stewardship plan

4.1.1 Evidence of compliance legal and regulatory requirements with regards to water balance, water management and Important Water related areas

REF049: Approvas of local environmental protection authority regarding Career projects

REF050: Pollutant discharge permit

REF051: Agreement signed between Career and Guangda Water Affairs Group regarding its wastewater treatment




REF067: Records of Career’s rectification of non-compliance

4.1.2 Evidence of efforts to provide safe drinking water and sanitation where stakeholders have an unmet human right

REF052: Test report for drinking water quality of secondary water supply in July 2018

4.2.1 and 4.2.2

Evidence that the site water balance targets are met. If in a water scarcity situation, also evidence that there is a continuous decrease in water withdrawals



4.2.3 Only in scarcity situations, evidence of no net increase in water scarcity

It is not a water scares catchment.


4.3.1 Evidence that shows that water quality targets are met REF016: Career Water Stewardship Report


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4.3.2 For water quality stressed catchments only: evidence of continual improvement or best practice

It is not a water quality stressed catchment.

4.3.3 For water quality stressed catchments only and where the site wishes to increase effluent levels of water quality parameters: evidence of no net degradation in water quality in the catchment

It is not a water quality stressed catchment.

4.4.1 Evidence that targets for the Important Water related Areas have been met

Although the ecological red line areas of Jiangsu Province and Kunshan City had defined in the catchment, Career is located at the downstream of the ecological red line areas. Therefore, it has little influence on the water related areas for the catchment.

4.4.2 Where Important Water Related Areas is a shared water challenge, evidence that best practice are met.

Please refer to the indicator 4.4.1.

4.5.1 Evidence of the site’s on-going efforts to contribute to good catchment governance (evidence of coordination and cooperation with catchment management authorities)

REF053: Contact List of Local Catchment Management Authorities

RFE054: Records of participating in water-related meetings organized by local environmental protection authority

4.5.2 Only for weak water governance catchments: evidence of continual improvement/best practice

As one of the most developed provinces and the most developed city in China, Jiangsu Province and Kunshan City have paid great attention to water protection. Therefore, the catchment where Career is located does not belong to a weak water governance catchment.

4.6.1 Evidence that site product suppliers and water related service providers have been contacted and are taking actions to contribute to the water stewardship outcomes



4.7.1 List of actions to ensure WASH on site REF059:Pictures of Employees’ Dormitoriy

REF060:Test report for drinking water quality in 2017


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4.8.1 Evidence and list of key owners of the water infrastructure and content of message that has been conveyed related to the site risks and shared water challenges



REF061: Record of sharing water stewardship plan and water stewardship strategy with local environmental protection authority

REF062: Record of sharing water stewardship plan and water stewardship strategy with Guangda Water Affairs Group

5 Evaluation (core) “against the actions taken in the implementation of the plan”. Expectation of such an evaluation at least annually. For the first implementation, look for evidence that these indicators are included in the plan.

5.1.1 Post implementation data and discussion on performance (water risk)

REF063: Summary of annual management meeting in 2017

5.1.2 Total amount of water related costs, cost saving and value creation with regards to the actions of criteria 3.2


5.1.3 Updated data for indicator 2.4.7 on catchment shared value creation

This is the initial assessment.

5.2.1 Evidence of evaluation of water related emergencies and extreme events (effectiveness of preventive and corrective measures) and inclusion of lessons learnt in the updated action plan

No water related emergencies and extreme events occurred at the site in recent years.

5.3.1 Feedback and commentaries from stakeholders on the site water stewardship performance and factor input in the updated action plan

REF064: Summary of satisfaction survey regarding Career’s water stewardship

5.4.1 Update of the plan with the inputs from indicators 5.1.1, 5.1.2, 5.2.1, 5.3.1. Update does not apply for the first implementation/audit

This is the initial assessment.

6 Disclosure and communication of performance (core)


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6.1.1

Disclosure and public availability of summary related to the general governance structure of the site’s management with names of those accountable for compliance with water related laws and regulations

REF065: Career water-related governance structure


6.2.1 Disclosure of summary of site’s water stewardship results against the targets




6.3.1

Disclosure and public availability of efforts to address shared challenges and report on actions taken to help address these challenges and engage stakeholders, including public sector agencies

REF061: Record of sharing water stewardship plan and water stewardship strategy with local environmental protection authority

6.4.1 Document and make available a list any site water compliance violation together with the corrective action implemented to prevent further occurrence.

On 18 June 2018, Career received a rectification notice issued by local environmental protection authority regarding its no EIA approvals for one gilding production line and one tinning production line, and part of industrial effluent discharged into rainwater pipeline network. The deadline for the rectification was scheduled on 31 July 2018. Career paid great attention to the rectification notice, and rectified its non-compliance activities on time. Meanwhile Career keeps close contact with local environmental protection authority, and its final rectification results had been approved by local environmental protection authority and made public. Career maintains the relevant records.


6.5.1 Evidence of awareness related initiatives at site level with dates of communications and, if possible, level of awareness

REF068: Attendance list for training of water stewardship

REF069 On-site traing pictures

REF070: Career water stewardship training materials


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7 AUDIT FINDINGS

Five minor non-conformities were raised during the audit process. They were considered partially meeting the AWS Core criterion requirement,

and some small adjustments were requested to make to the documentation in order to be considered fully compliant. Table 7.1 shows the

details of the minor non-conformities and required new information.

Table 7.1 Minor Non-Conformities Raised during the AWS Audit Process

No. Type Ref. Details Response by Career Relevant References

1 Minor Non-Conformance

01MINCAR Indicator 2.3.1 List of relevant aspects of catchment plan(s), significant publicly led initiatives and/or relevant waterrelated public policy goals for the site

Career has established an update list of catchment plans, scenarios and notifications. However, no aspects of the catchment plans related to Career’s water stewardship were identified, especially for some key catchment plans such as the Conservation Plan for Ecological Red Line Areas of Jiangsu Province and the Implementation Plan for Ecological Red Line Areas of Kunshan City.

On 22 November 2018, Career provided a corrective action plan for 01MINCAR, which consisted of root analysis, corrective actions, responsible person and implementation deadline. Meanwhile, Career provided the evidence of completing the corrective actions.

Relevant articles of catchment plans, scenarios and notifications applicable to Career’s water stewardship had been identified, and a corresponding list was developed.

REF013: List of Catchment Plans, Scenarios and Notifications updated in 2018 (with relevant articles)



02MINCAR Indicator 2.4.1 Copies of existing water stewardship and incident response plans

Currently, the national and local environmental protection authorities have established a lot of water quality monitoring sections at the rivers in the catchment. If the deterioration of water quality is monitored, the national or local


Career evaluated the water related emergencies caused by the production restriction, suspension or even shutdown required by local environmental protection




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environmental protection authorities will launch their emergency response plans, which may result in the production restriction, suspension or even shutdown of a factory to reduce effluent discharge. However, Career fails to evaluate this water related emergencies and develop its response plan.

authority because of the deterioration of river water quality in the catchment and developed relevant response plan, which had been integrated into Career’s Procedure for Emergency Control.


03MINCAR Indicator 2.5.2 List of outsourced services that consume water or affect water quality.

Career has collected the indirect water use and wastewater discharge of its main suppliers of raw materials and chemicals. However, no test report of wastewater discharge is collected by Career regarding its main suppliers of raw materials and chemicals.


Career collected the test reports of wastewater discharge from YASEN and SONGYANG, two major suppliers located in the same catchment. The testing results confirmed their compliance with national and local wastewater discharge standards. In addition, Career said that they will optimize its management of suppliers and more attention will be paid to their water-related performance in 2019.

REF071: Test report for treated effluent of YASEN in 2018

REF072: Test report for treated effluent of SONGYANG in 2018



04MINCAR Indicator 4.6.1 List of suppliers and service providers, along with the actions they have taken as a result of the site’s engagement relating to indirect water use

Career has asked its suppliers to provide water stewardship plan. As one of Career’s main suppliers, YASEN is implementing a project regarding the reuse of steam condensate. However, no


Career collected YASEN’s water saving scheme which consists of responsible person, implementation schedule and cost analysis.

REF073: Summary Table of Energy & Water Efficient Projects of YASEN in 2018



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specific implementation scheme was collected by Career.


05MINCAR Indicator 6.1.1 Disclosed and publicly available summary of governance at the site, including those accountable for compliance with water-related laws and regulations

Although Career has established its water-related governance structure and contact information, it failed to disclose relevant information.


Career has disclosed its water-related governance structure and contact information on Career Group’s website:





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8 SUMMARY

Based on the review of documents presented by Career, the interview with Career’s

managers and employees, the interview with local stakeholders, and the site

reconnaissance, Career has paid great attention to its water stewardship. A considerable

quantity of effort and work has been put into the preparation for the audit of AWS

certification.

Five minor non-conformities were raised during the audit process. They were considered

partially meeting the AWS Core criterion requirement, and some small adjustments were

requested to make to the documentation in order to be considered fully compliant. Career

provided SGS additional information and documents after the completion of site visit to

ascertain its compliance to the AWS Standard. No further action was deemed necessary.

All evidence submitted to SGS in response to the findings was reviewed and evaluated for

compliance to the AWS standard. All actions were accepted as sufficient to demonstrate

compliance and the findings were cleared and closed.


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9 OPPORTUNITIES FOR IMPROVEMENT

This is the initial conformity assessment for Career against the AWS Standard, and more

attention is paid to the documented plan and implementation to date. Less focus was placed

on the evaluation of Career’s performance against the indicators as this was the first year of

operation under the intention of conformity to the AWS Standard. Therefore, it allows for

many areas for improvement going forward.

The future audits will additionally evaluate Career’s performance against the AWS Standard

indicators and how this is monitored and presented as compliance. Thus, SGS recommends

that Career develop practicable ways to monitor its performance against the AWS Standard

indicators, and keep relevant records in anticipation of future audits.


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10 CONCLUSIONS AND RECOMMANDATIONS

Given the review of evidence presented and the site reconnaissance performed at Career,

SGS recommends that Career be awarded the AWS Core Certified status with a surveillance

audit interval of annual frequency.


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11 REFERENCES

REF001: Water Stewardship Commitment




REF005: Water Stewardship Policy

REF006: Layout of Career Factory

REF007: Map of Water Supply and Wastewater Discharge

REF008: Map of Water System in the Catchment of Wusongjiang River

REF009: Catchment of Tai Lake

REF010: Catchment of Wusongjiang River

REF011: List of Stakeholders

REF012: EIA Report developed for Career’s construction project

REF013: List of Catchment Plans, Scenarios and Notifications updated in 2018


REF015: List of national and local applicable laws, regulations and standards related to

water and water use rights updated in 2018









REF024: Emergency Response Plan for environmental emergencies registered in local

environmental protection authority



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REF026: Analysis of Water Balance in July 2018

REF027: Analysis of Water Balance in August 2018

REF028: Analysis of Water Balance in September 2018

REF029: Analysis of Water Balance in October 2018

REF030: Summary Analysis of Water Balance from Janaury to October 2018

REF031: Pictures of online monitoring devices




REF035: List of chemicals

REF036: Emergency response plan for chemical leakage

REF037: Analysis of water-related costs

REF038: List of suppliers of raw materials and chemicals including their water use and

related water risk


REF040: List of Shared Water Challenges in the Catchment


REF042: Controlling Procedure for Laws, Regulations and Other Requirements (EP04)

REF043: Table of compliance review


REF045: Procedure for the Management of Objectives and Targets (EP05)

REF046: Table for Tracking the Achievement of Objectives and Targets (EP05-F2)


REF048: Record of communication with local environmental protection authority via email

REF049: Approvas of local environmental protection authority regarding Career projects

REF050: Pollutant discharge permit

REF051: Agreement signed between Career and Guangda Water Affairs Group regarding its

wastewater treatment


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REF053: Contact List of Local Catchment Management Authorities

RFE054: Records of participating in water-related meetings organized by local environmental

protection authority


REF059:Pictures of Employees’ Dormitoriy

REF060:Test report for drinking water quality in 2017

REF061: Record of sharing water stewardship plan and water stewardship strategy with local

environmental protection authority

REF062: Record of sharing water stewardship plan and water stewardship strategy with

Guangda Water Affairs Group


REF064: Summary of satisfaction survey regarding Career’s water stewardship

REF065: Career water-related governance structure



REF068: Attendance list for training of water stewardship

REF069 On-site traing pictures

REF070: Career water stewardship training materials

REF071: Test report for treated effluent of YASEN in 2018

REF072: Test report for treated effluent of SONGYANG in 2018

REF073: Summary Table of Energy & Water Efficient Projects of YASEN in 2018


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APPENDIX 1 SGS AUDIT CHECKLIST


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APPENDIX 2 CAREER ACTION PLANS RESPONSE TO FINDINGS

alliance for water stewardship Conformity assessment report · intention to pursue AWS...

Documents

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