RBA
RBA Code of Conduct implementation support
The RBA Code of Conduct covers labor, health and safety, environment, ethics, and management systems. Vosurein reviews recruitment, attendance and payroll, operational risks, and management records at each site to identify gaps between procedures and actual working conditions. We help plan improvements and prepare for audits. If a customer requires VAP, we plan site reviews, records preparation, and follow-up corrective actions around the applicable program.
For Your Business
Who this service is for and when to start
When a brand customer requests an assessment, or when preparing for a site assessment or following up on previous findings, first confirm whether the requirement is a self-assessment questionnaire, VAP, or the customer’s own audit. Each program has its own scope, report-sharing arrangements, and process for closing findings. The RBA Code originated in the electronics industry and is also used in other industries.
Sites with migrant workers, agency workers, dormitories, or contracted operations should clarify recruitment and operational responsibilities early, including which internal teams and external parties need to take part. If improvements have already been requested, identify urgent risks and deadlines before planning root cause analysis and checks on whether the actions work.
Before the official evaluation date is confirmed, the existing system and records can be reviewed to see if they sufficiently reflect site conditions, leaving necessary time for equipment, procedures, or external collaboration.
The Challenge
Common challenges faced by businesses
The documented procedures may differ from the actual experience of shifts, production lines, or personnel. If recruitment contracts, attendance, and wages are stored separately without cross-checking, problems often only surface during on-site evaluation.
We trace how the same issue is handled across different processes. For example, attendance discrepancies may involve shift schedules, production capacity, and payroll calculations, requiring HR and site supervisors to review them together. Workers of different nationalities or employment arrangements may also follow different recruitment and onboarding processes. These examples show how consulting helps identify gaps.
Improvements also need to address the causes of recurring issues. In addition to correcting individual records, it is necessary to confirm whether procedures, responsibilities, and daily checks need adjustment and to document subsequent follow-up results.
Our Approach
Methods and applicable requirements
Code and assessment requirements. At the time of this source review, RBA Code of Conduct 8.0 had been effective since 1 January 2024, covering labour, health and safety, environment, ethics and management systems. A formal assessment also requires checking the VAP or customer assessment documents, local site regulations and additional requirements. RBA specifies that its English version prevails where translations differ.
How to review the five areas. Labor-related work involves recruitment, working hours, remuneration, and equal treatment; health, safety, and environment are linked to equipment, operations, and emergency records; ethics involves integrity, information, and reporting; management systems are used to maintain risk identification, education, audits, and corrective actions. Existing ISO systems can provide part of the foundation but still need to be cross-checked against other applicable items.
VAP Assessment Method. RBA-approved independent third parties follow the procedure to conduct document review, management and employee interviews, and on-site observation. The role of Vosurein is to assist companies in preparation and improvement, while formal assessment and result determination are carried out according to the applicable procedure.
Corrective Actions and Closure. VAP findings are classified by severity as minor, major, or priority. A corrective action plan (CAP) must address the issue, its cause, and prevention of recurrence. After implementing the actions, the company submits evidence for review under the applicable program. Uploading evidence does not mean the assessor has confirmed closure; follow-up is still needed.
Process
Consulting scope and process
Review site requirements and current practices
Read customer notifications, guidelines, and assessment plans, and verify site activities, personnel, and previous findings. Arrange departmental interviews and document review, first listing items with deadlines or requiring immediate attention, then plan the scope of inspection.
Review gaps between procedures and site practices
Check procedures, records, and on-site practices for recruitment, working hours and wages, grievances, occupational safety, environment, and ethics management. When inconsistencies are found, identify which shifts, personnel, or suppliers are involved, and which units need to handle them jointly.
Implement improvements and document evidence
Clarify with the company the causes, measures, responsible persons, and deadlines, and assist in adjusting procedures and daily inspections. After correction, confirm actual implementation, retain improvement and follow-up records, which are used to judge whether similar problems are likely to recur.
Internal Checks and Audit Preparation
Review progress and site records, and confirm the document index, interview contacts, and site preparations. After the formal assessment, plan CAP work and follow-up reviews based on the findings. Closure follows the applicable program’s requirements.
Preparation
What documents do companies need to prepare?
- Site and requirements: Organization and scope of operations, personnel and shift profiles, customer notifications, applicable evaluation plans, previous reports, and CAP status.
- Labor and Recruitment: Workforce categories, including directly hired, agency, and migrant workers; recruitment and agency arrangements; contracts; attendance and payroll; and grievance records.
- Environment and Occupational Safety: Records of operational risks, training and emergency response, equipment or operational inspections, applicable permits, and environmental management, with the sites and periods covered clearly identified.
- Ethics and Management: Policy and reporting procedures, division of responsibilities, supplier management, internal audit, management review, and improvement tracking records.
For the initial review, provide a list of available records and their coverage periods, then agree on sampling based on the site and assessment scheme. Share personal or sensitive information only as necessary, retaining traceability to the source records.
Project Planning
Estimating time and cost
The consulting workload depends on site and workforce size, shifts, recruitment methods and activities such as dormitory or contractor management. Previous findings and current records help determine the site-review priorities, depth of improvements and number of review rounds.
If equipment, dormitory conditions, attendance systems, or external recruitment agencies are involved, engineering, procurement, and coordination time must be included. The schedule will include current status inspections, implementation of measures, and effectiveness confirmation, with formal evaluations arranged according to the plan.
Agree separate fees for consulting, site visits, translation and third-party assessment. Providing the audit notice, site profile and CAP status helps define the work and completion criteria.
FAQ
Frequently asked questions
How does RBA consulting differ from a VAP audit?
Consulting helps companies prepare and make improvements. VAP is an assessment conducted by an independent third party under the program’s requirements. Consulting outcomes cannot replace audit results.
Do we still need to prepare if we have ISO 45001 or ISO 14001?
Existing systems provide part of the management foundation, but the RBA Code also covers labor and ethics. Each applicable requirement still needs to be checked against the site’s practices and the customer’s requirements.
Is organizing documents enough?
Not enough. On-site operations and interviews are also sources of assessment information. Procedures, execution, and records must be consistent; paper policies cannot replace actual improvements.
When findings arise, should we update documents or improve site practices first?
Assess risks and issues requiring immediate action first, then identify causes and plan corrective measures. Records should accurately reflect improvements, without using additional paperwork to conceal unresolved problems.
Can consulting guarantee an audit with no findings?
No. A site assessment reflects conditions at a particular point in time, so ongoing management remains necessary. Consulting can help address gaps and check evidence of improvements, but cannot guarantee the assessment outcome.
Does completing the self-assessment questionnaire (SAQ) mean we have passed VAP?
No. Self-assessment is used to collect company responses, while VAP includes an independent site assessment. Whether further audits are needed, when to arrange them, and how to share the results should be confirmed according to the client and applicable program.
Should we include records for agency workers, migrant workers, and recruitment agencies?
If it is related to site operations and the applicable assessment scope, responsibilities should be identified and documented; it is not enough to review only the company’s directly hired employees. Recruitment costs, contracts, and actual practices can be cross-checked from the agency, the company, and the employee sides.
How can consulting help with findings from a formal audit?
Start with the assessor’s findings and deadlines, then confirm the causes, responsible people, and actions. Address urgent risks first, followed by changes to management procedures and checks on effectiveness. Closure is determined through the applicable assessment process.
Related
Related services and enquiries
Please provide an overview of the site, personnel, and shifts, client audit notifications, and previous deficiencies to facilitate arranging on-site review and improvement work.Consult with Vosurein
Content checked: . Applicable versions and requirements depend on the company’s circumstances.
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