Alliance for Water Stewardship Comformity Assessment Report Prepared for Flexium Interconnect (Kunshan), Inc. (AWS-010-INT-CAB-00-08-00015-0075) Prepared by: SGS SGS Ref.: CN/SZH Version: 1 Date: Dec. 8, 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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Alliance for Water Stewardship Comformity Assessment Report
Prepared for Flexium Interconnect (Kunshan), Inc.
(AWS-010-INT-CAB-00-08-00015-0075)
Prepared by: SGS
SGS Ref.: CN/SZH
Version: 1
Date: Dec. 8, 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 Jason Chang-Chien
REPORT TITLE ALLIANCE FOR WATER STEWARDSHIP CONFORMITY ASSESSMENT REPORT
DATE SUBMITTED: Dec. 8, 2018
CLIENT: Jason Chang-Chien
Facility Manager, Flexium Interconnect (Kunshan), Inc.
T +86 0512 5777 5599 Ext. 1273
No.1399, Hanpu Road, Yushan Town, Kunshan City, Jiangsu Province, P. R. China
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.
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 Tai Lake, the catchment of
Wusongjiang River, and the water system in the catchment of Wusongjiang River.
December 8, 2018 [ALLIANCE FOR WATER STEWARDSHIP CONFORMITY ASSESSMENT REPORT]
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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
Flexium
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Figure 4.3 The Water System in the Catchment of Wusongjiang River
In addition, to protect drinking water sources and the 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
Flexium
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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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Page 17 of 48
Figure 4.6 shows Flexium’s water supply and wastewater discharge.
Figure 4.6 Flexium’s Water Supply and Wastewater Discharge (Blue: Water Supply; Orange: Wastewater)
Kuilei
Lake
Yangtze
River
Wusongjiang River
Qingyanggang
River
Taicangtang
River
Hanputang
River
Kunshan North
District Wastewater
Treatment Plant
Flexium
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5 SUMMARY OF SHARED WATER CHALLENGES
Flexium has identified general shared challenges in the catchment and these are listed in Table 5.1.
Table 5.1.Detailed Shared Water Challenges for Flexium
No. Water Challenge Associated Government Authority initiative/Plan*
Relevant/Rationale for Stakeholders Relevant/Rationale for Site Priority (1-4) Rationale for Prioritization
1 Potentially increased levels of water shortage
Rational use of existing water resources and protection of water sources
Increase the imbalance between drinking water supply and demand, result in the rising of water costs
Increase the imbalance between drinking water supply and demand, result in the rising of water costs
2 1: Basically not concerned and affected 2: Occasionally concerned with small influence 3: Concerned but not very often. The scope of influence is controllable, and the results are not serious. 4: Frequently concerned with high attention. The scope of influence is wide, and the results are serious.
2 Insufficient water treatment infrastructure
New sewage treatment facilities may be built to collect and treat domestic sewage
Increase the safety risks of local communities’ drinking water
Insufficient water treatment facilities, and noncompliance of water quality in the catchment may result in the production restriction, suspension or even shutdown of a factory.
2
3 Groundwater and surface water pollution risk
Conduct groundwater and surface water quality surveys, introduce relevant policies and regulations, and incorporate environmental protection supervision system in environmental management
The health of community residents may be affected; and
Residents may complain to the local government or environmental protection authority if they discover water pollution.
Production restriction, suspension or even shutdown may be required for enterprises in the catchment.
3
4 Water price Raising water price Resulting in the higher living costs for local residents and affecting their life quality
Factory manufacturing costs increase and its competitiveness declines
2
5 More difficult to obtain water license
The priority is to meet the water use of local residents,and ensure the normal production water of enterprises.
Affect local communities’ obtaining of daily domestic water
Affecting an enterprise’s normal productionand its competitiveness
2
6 More stringent requirements for water efficiency and wastewater discharge
Setting higher water efficiency rate and more stringent wastewater discharge standards
Residents will be less affected by water pollution; and
Residents may cooperate with local governments and environmental protection agencies to set more stringent standards so as to reduce the discharge of water pollutants.
Increase the company’s cost of water treatment such as the costs for chemical agents; and
The company may need to invest more for improving the efficiency of its water treatment facilities.
4
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No. Water Challenge Associated Government Authority initiative/Plan*
Relevant/Rationale for Stakeholders Relevant/Rationale for Site Priority (1-4) Rationale for Prioritization
7 Inadequate legal and regulatory supervision
Enhance supervision because the existing regulations are not fully and strictly enforced.
The living environment of residents is degraded and their health is affected. If residents discover environmental violations, they may complain to local governments or environmental protection agencies.
The company shall manage its activities according to relevant environmental regulations; and
The company shall conduct more stringent management according to the requirements of customers or international standards. Some requirements may be more stringent than laws and regulations.
4
8 Policy uncertainty Specify relevant policies and meet the requirements of the public
Influencing residents, causing their complaints to local governments or environmental agencies
The company shall manage its activities according to relevant environmental regulations; and
The company shall conduct more strict management according to the requirements of customers or international standards. Some requirements may be more stringent than laws and regulations.
4
9 Increased incidence of water-related diseases
Strengthen pollution control and reduce risk factors
Influencing residents, causing their complaints to local governments or environmental agencies
The surrounding residents will conduct environmental supervision on the enterprise;
The company must meet pollution discharge standards and take social responsibility; and
The enterprise must publicize its relevant data of water environment management.
4
* 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
6.1 CORE AWS INDICATORS
As per the requirement set out in the Section 2.11.3.1 of the AWS Certification Requirements, the following table 6.1 presents all the CORE
AWS indicators with the relevant reviewed evidence provided by Flexium.
Table 6.1 Evidence Reviewed by SGS Against Each CORE AWS Indicator
1.1 Leadership commitment on water stewardship As Flexium’s parent company, Flexium Interconnect, Inc. (Flexium Group) provides the leadership commitment on water stewardship for Flexium in Kunshan. Flexium Group’s CEO has signed both the “Water Stewardship Policy” and the “Water Stewardship Commitment” developed for Flexium in Kunshan, which are made public on Flexium Group’s website. Please refer to the following website:
http://www.flexium.com.cn/big5/green_aws.asp
REF001: Water Stewardship Policy
REF002: 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 the CEO of Flexium Group, the factory manager of Flexium in Kunshan and the CSR management representative of Flexium Group. This commitment has been displayed on the website of Flexium Group:
http://www.flexium.com.cn/big5/green_aws.asp
and posted on the bulletin board respectively installed at Flexium Kunshan factory, local environmental protection authority (EPA) and nearby community (Lvpeiyuan Community).
REF003: Bulletin Board Installed at Employees’ Canteen of Flexium
REF004: Bulletin Board Installed at Local Environmental Protection Authority
REF005: Bulletin Board Installed at Lvpeiyuan Community
1.2.1 Has the organisation elaborated, agreed upon and discloses a water stewardship policy?
A water stewardship policy has been signed by the CEO of Flexium Group and made public on the following website:
http://www.flexium.com.cn/big5/green_aws.asp.
REF001: Water Stewardship Policy
2 Water challenges (core)
2.1.1 Site boundaries (map) REF006: Layout of Flexium 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 Flexium’s construction project dated in August 2018 (Page 10 and 15: description of project impact on water environment)
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)
REF017: Report of Background Information for Flexium’s Water Risks, Opportunities and Challenges (Section 3.2: Water balance for the catchment)
2.3.4 Appropriate and credibly measured data to represent the physical, chemical and biological status of the site’s water source(s) by temporally relevant time unit, and commentary on any anticipated future changes in water quality
REF017: Report of Background Information for Flexium’s Water Risks, Opportunities and Challenges (Section 3.3: Water quality for the catchment)
2.3.5 Water related areas for the catchment: identification of the areas and description of current status and trends
REF017: Report of Background Information for Flexium’s Water Risks, Opportunities and Challenges (Section 3.4: Water related areas for the catchment)
REF018: Conservation Plan for Ecological Red Line Areas of Jiangsu Province
REF019: Implementation Plan for Ecological Red Line Areas of Kunshan City
REF020: Distribution Map of Kunshan Ecological Conservation Red Lines
EEF021: 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
REF017: Report of Background Information for Flexium’s Water Risks, Opportunities and Challenges (Section 3.5: Infrastructure for the catchment )
2.4.1 Water data for the site: water stewardship and incident response plan
REF022: Water Stewardship Plan
REF023: Emergency Response Plan for Water Interruption, Water Resources Contamination and Water Pipeline Frozen
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)
REF025: Water Balance-Flexium Kunshan-2017-1st-Half-Year
REF026: Water Balance-Flexium Kunshan-2017-2nd-Half-Year
REF027: Water Balance-Flexium Kunshan-2018-1st-Half-Year
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REF029: Evaluation Report for Recycle Ratio of Industrial Water
2.4.3 Water data for the site: water quality (direct and outsourced water effluent and also possible pollution sources)
REF030: Pictures of online monitoring devices
REF031: Test report for treated effluent in July 2018
REF032: Test report for treated effluent in August 2018
REF033: 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)
REF034: List of chemicals
REF035: Emergency response plan for chemical leakage and hazardous waste
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
REF017: Report of Background Information for Flexium’s Water Risks, Opportunities and Challenges (Section 3.4: Water related areas for the catchment)
REF018: Conservation Plan for Ecological Red Line Areas of Jiangsu Province
REF019: Implementation Plan for Ecological Red Line Areas of Kunshan City
REF020: Distribution Map of Kunshan Ecological Conservation Red Lines
EEF021: Kunshan Conservation Areas of Drinking Water
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
REF036: Water-related costs
REF037: Pictures for providing water-related education for local schools
REF038: Pictures for providing bottled drinking water for local fire brigade
2.5.1 Indirect water use: list primary inputs with their associated (annual) water use and, if possible, the origin of the water
REF039: List of suppliers of raw materials and customers, their water use, wastewater discharge and associated 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.
REF039: List of suppliers of raw materials and customers, their water use, wastewater discharge and associated water risk
REF040: Response to Finding 03MINCAR
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2.6.1 List of shared water challenges that affect the catchment REF041: 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
REF042: Flexium Water Risk Profile and Water-Related Opportunities
2.7.2 Site risks and opportunities: list water related opportunities REF042: Flexium Water Risk Profile and Water-Related Opportunities
2.7.3 Site risks and opportunities: analysis of potential savings/value creation that could result from actions to address the challenges. Look at the actions in the context of water quality, water related areas, water governance, etc.
REF042: Flexium Water Risk Profile and Water-Related Opportunities
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
REF043: Procedure for Identification of Laws, Regulations and Other Requirements and Compliance Assessment
3.2.1 Stewardship strategy that contains water challenges within the catchment and risks for the site together with the site responses
REF044: Flexium CSR Report Progress
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
REF022: Water Stewardship Plan
REF045: Tragets for water use and wastewater discharge in 2018
b) Proposed actions to achieve the targets and names of individuals responsible for each
REF022: Water Stewardship Plan
c) A budget for the proposed actions with a cost benefit analysis REF022: Water Stewardship Plan
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d) Links to the desired results in terms of risks/opportunities, water stewardship outcome and shared water challenges
REF022: Water Stewardship Plan
3.3.1 Evidence of responsiveness and resilience to water related risks embedded in the site’s incident response plan
REF023: Emergency Response Plan for Water Interruption, Water Resources Contamination and Water Pipeline Frozen
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
REF004: Bulletin Board Installed at Local Environmental Protection Authority
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
REF046: Approvas of local environmental protection authority regarding Flexium projects
REF047: Pollutant discharge permit
REF031: Test report for treated effluent in July 2018
REF032: Test report for treated effluent in August 2018
REF033: Test report for treated effluent in October 2018
4.1.2 Evidence of efforts to provide safe drinking water and sanitation where stakeholders have an unmet human right
REF048: 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
REF017: Report of Background Information for Flexium’s Water Risks, Opportunities and Challenges
RFE028: Water Balance Test Report
REF029: Evaluation Report for Recycle Ratio of Industrial Water
4.2.3 Only in scarcity situations, evidence of no net increase in water scarcity
It is not a water scares catchment.
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REF017: Report of Background Information for Flexium’s Water Risks, Opportunities and Challenges
4.3.1 Evidence that shows that water quality targets are met REF048: Test report for drinking water quality of secondary water supply in July 2018
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, Flexium 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)
REF049: Contact List of Local Catchment Management Authorities
RFE050: Records of communication with local government authorities including water-related departments
REF051: Test report for water quality of Hanputang River in 2018
REF052: Test report for water quality of Taicangtang River in 2017
REF053: Test report for sediment of Hanputang River in 2018
REF054: Test report for sediment of Taicangtang River in 2017
4.5.2 Only for weak water governance catchments: evidence of continual improvement/best practice
To control and mitigate environmental pollution, the central government established an environmental protection supervision committee in 2016, which is responsible for promoting environmental protection supervision in China including the check of local environmental protection authorities’ supervision work. Kunshan environmental protection authority started environmental protection supervision in 2017. To meet national and local
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environmental requirements, Flexium has taken a series of measures to continually improve its water stewardship including the “zero” discharge of nitrogen and phosphorus and increase the recycle ratio of industrial water to 91.35%.
REF029: Evaluation Report for Recycle Ratio of Industrial Water
REF031: Test report for treated effluent in July 2018
REF032: Test report for treated effluent in August 2018
REF033: Test report for treated effluent in October 2018
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
REF039: List of suppliers of raw materials and customers, their water use, wastewater discharge and associated water risk
RFE055: Training records for suppliers of raw materials and customers
REF056: Training materials for suppliers of raw materials and customers
REF056: Water Stewardship Improvement Plan of Baoli Electronic (Kunshan) Co., Ltd. in 2018
REF057: Water Stewardship Improvement Plan of Dongoyuyue (Suzhou) Electronic Technology and New Materials Co., Ltd. in 2018
REF058: Water Stewardship Improvement Plan of Hengmingda Electronic Technology Co., Ltd. in 2018
REF059: Water Stewardship Improvement Plan of Keboxi Electronic Material (Zhang Jiagang) Co., Ltd. in 2018
REF060: Water Stewardship Improvement Plan of Luchang Fine Chemical (Kunshan) Co., Ltd. in 2018
REF061: Water Stewardship Improvement Plan of Jingying Electronic Co., Ltd. in 2018
REF062: Water Stewardship Improvement Plan of Luchang Fine Chemical (Kunshan) Co., Ltd. in 2018
REF063: Water Stewardship Improvement Plan of Suzhou Tianlida Adhensives Co., Ltd. in 2018
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4.7.1 List of actions to ensure WASH on site REF065:Pictures of Employees’ Dormitoriy
REF066:Test report for water quality of employees’ canteen
REF067: Test report for water quality of employees’ drinking water dispenser
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
REF022: Water Stewardship Plan
REF004: Bulletin Board Installed at Local Environmental Protection Authority
RFE050: Records of communication with local government authorities including water-related departments
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)
REF022: Water Stewardship Plan
REF068: Review Report of Water Stewardship in 2018
REF069: Attendee list of water stewardship review meeting
5.1.2 Total amount of water related costs, cost saving and value creation with regards to the actions of criteria 3.2
REF022: Water Stewardship Plan
REF068: Review Report of Water Stewardship in 2018
REF069: Attendee list of water stewardship review meeting
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
REF070: Response to Finding 04MINCAR
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5.3.1 Feedback and commentaries from stakeholders on the site water stewardship performance and factor input in the updated action plan
REF071: Form of satisfaction survey
REF072: Response to Finding 05MINCAR
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)
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
REF002: Water Stewardship Commitment
REF003: Bulletin Board Installed at Employees’ Canteen of Flexium
REF004: Bulletin Board Installed at Local Environmental Protection Authority
REF005: Bulletin Board Installed at Lvpeiyuan Community
6.2.1 Disclosure of summary of site’s water stewardship results against the targets
REF043: Flexium CSR Report Progress
REF002: Water Stewardship Commitment
REF003: Bulletin Board Installed at Employees’ Canteen of Flexium
REF004: Bulletin Board Installed at Local Environmental Protection Authority
REF005: Bulletin Board Installed at Lvpeiyuan Community
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
REF003: Bulletin Board Installed at Employees’ Canteen of Flexium
REF004: Bulletin Board Installed at Local Environmental Protection Authority
REF005: Bulletin Board Installed at Lvpeiyuan Community
6.4.1 Document and make available a list any site water compliance violation together with the corrective action implemented to prevent further occurrence.
No regulatory violations occurred at Flexium to date
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1.3 Has the organisation initiated any action to further the AWS?
Flexium actively pursues the Alliance for Water Stewardship certification, and has officially registered AWS as seeking certification to the AWS standard.
http://a4ws.org/
REF076: Screenshot of Flexium registered at AWS for certification
3
1.5 Is there a water stewardship commitment from the most senior executive of the organisation?
A water stewardship commitment to follow all the AWS core criteria has been signed by the CEO of Flexium Group. This commitment has been displayed on the website of Flexium Group:
http://www.flexium.com.cn/big5/green_aws.asp
and posted on the bulletin board respectively installed at Flexium Kunshan factory, local environmental protection authority (EPA) and nearby community (Lvpeiyuan Community).
REF003: Bulletin Board Installed at Employees’ Canteen of Flexium
REF004: Bulletin Board Installed at Local Environmental Protection Authority
REF005: Bulletin Board Installed at Lvpeiyuan Community
1.6 Is there a commitment to assist with community water needs in time of stress?
A commitment to directly assisting with community water needs in times of scarcity has been signed by the CEO of Flexium Group, the factory manager of Flexium in Kunshan and the CSR management representative of Flexium Group. The commitment explicitly covers all AWS requirements. It has been publicly disclosed at the bulletin board respectively installed at Flexium Kunshan factory, local environmental protection authority (EPA) and nearby community (Lvpeiyuan Community). The commitment is also displayed at Flexium Group’s website.
http://www.flexium.com.cn/big5/green_aws.asp
According to the commitment, Flexium respects the rights of local communities. When the basic water demand of the communities cannot be met, it commits to continuously improving its water use, prioritizing the needs of the communities, and providing each of the stakeholders with daily access to water of 20 litres until their basic water needs are restored.
REF002: Water Stewardship Commitment
REF003: Bulletin Board Installed at Employees’ Canteen of Flexium
REF004: Bulletin Board Installed at Local Environmental Protection Authority
REF005: Bulletin Board Installed at Lvpeiyuan Community
8
2 Water challenges
2.9 Evidence of water data gathering beyond the standard requirements, especially in highly data deficient environments.
To help the local environmental protection authority to fully know surface water quality in the catchment and make up the data deficient for some water bodies, Flexium has voluntarily entrusted China Test (Jiangsu) Testing Technology Co., Ltd., a third-party with the qualification of China Metrology Accreditation to monitor the water quality and sediment of Hanputang River and Taicangtang River on a yearly basis since 2016. The testing parameters of water include TN and TP. The testing parameters of sediment consist of Hg, Ni, Cr, Cd, As, Se, Pb, Cu, Sb,
Ba, cyanide, benzene, toluene, xylene and trichloromethane. We randomly reviewed the testing reports in 2017 and 2018 during site visit.
REF051: Test report for water quality of Hanputang River in 2018
REF052: Test report for water quality of Taicangtang River in 2017
REF053: Test report for sediment of Hanputang River in 2018
REF054: Test report for sediment of Taicangtang River in 2017
2.12 Site contribution to groundwater recharge and/or environmental flows restoration in coordination with relevant governmental agencies.
Although Flexium does not extract groundwater or directly recharge groundwater, cooperating with local environmental protection authority, it has drilled 10 permanent wells at the site to monitor groundwater quality on a yearly basis. Jiansu Yuanyuan Testing Technology Co., Ltd., a third-party with the qualification of China Metrology Accreditation is entrusted to perform the testing of groundwater quality. The testing parameters include pH, TPH, TVOCs, SVOCs, Sb, As, Be, Cd, Cr, Cu, Hg, Pb, Ni, Sn, Ag, Tl and Zn. The testing results are disclosed on Jiangsu environmental monitoring information platform. We reviewed the testing report in 2018 during site visit.
REF077: Test report for groundwater quality in 2018
10
4 Implementation of the water stewardship plan
4.9.1 Evidence of quantified improvements in water balance from site-set baseline date.
According to the “Norm of Water Intake for industries, services and Livelihood” issued by Jiangsu Provincial Administration of Quality and Technology Supervision in 2015, the quantity of water intake for unit product of double-sided PCB is 1.08 m3/m2. To achieve this target, Flexium has taken a series of actions to improve its water balance. Based on the Water Balance Testing Report developed for Flexium by Suzhou Zhongjiexun Inspection and Testing Co., Ltd., a qualified third-party in June 2018, Flexium’s quantity of water intake for unit product of double-sided PCB in 2016 is 1.46 m3/m2, which is higher than the baseline standard. In 2017, the quantity of water intake for unit product of double-sided PCB is 0.63 m3/m2, which is lower than the baseline. Currently, Flexium’s quantity of water intake for unit product of double-sided PCB is about 0.62 m3/m2 (statistical data from January to June 2018).
RFE028: Water Balance Test Report
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4.9.2 Evidence showing that actions meet best practice expectations
Besides the quantity of water intake for unit product of double-sided PCB (about 0.62 m3/m2) is far lower than the standard (1.08 m3/m2) defined by Jiangsu Provincial Administration of Quality and Technology Supervision, Flexium has also obtained a great achievement in water recycle. According to the “Cleaner Production Standard for Printed Circuit Board Manufacturing (HJ-450-2008)” issued by the Ministry of Environmental Protection, the recycle ratio of industrial water for PCB manufacturing is defined as three levels. The first level (ratio≥55%) represents the advanced international level, the second level (ratio≥45%) represents advanced domestic level, and the third level (ratio≥30%) means the average domestic level. Based on the “Evaluation Report for Recycle Ratio of Industrial Water” developed by Suzhou Zhongjiexun Inspection and Testing Co., Ltd., a qualified third-party in June 2018, Flexium’s recycle ratio of industrial water is 91.35%, which is far higher than 55%, the first level defined by the Ministry of Environmental Protection. The report demonstrates Flexium’s good water stewardship.
RFE028: Water Balance Test Report
REF029: Evaluation Report for Recycle Ratio of Industrial Water
4.10.1 Evidence that targets have been met with regards to site water quality
Through technical renovation for its wastewater treatment, Flexium has realized the “zero” discharge of nitrogen and phosphorus. By employing the technology of low-temperature dewatering, the generation of sludge containing copper is greatly reduced. The technology used for treating wastewater containing nickle ensures the nickle concentration is lower than its detection limit. Both the review of testing reports and the on-site observation of online monitoring devices further confirmed the above information.
REF030: Pictures of online monitoring devices
REF031: Test report for treated effluent in July 2018
REF032: Test report for treated effluent in August 2018
REF033: Test report for treated effluent in October 2018
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4.10.2 Evidence that best practice has been achieved with respect to the site’s water quality targets as informed by stakeholders or industry benchmark. (8 points for both 4.10.1 and 4.10.2)
The practices implemented by Flexium to ensure the “zero” discharge of nitrogen and phosphorus, the reduction of sludge containing copper and the undetected level of nickle discharge have been accepted by local environmental protection authority and Apple, the purchaser of Flexium. The interviews with an official from local environmental protection
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authority and the water stewardship officer of Apple showed that they all give a high appraisal to Flexium with respect to its water quality targets.
REF078: Pictures of stakeholder consultation meeting
4.13.1 List of efforts to contribute to the development of regional industrial water related benchmarking and spreading best practice (3 points)
Because Flexium’s best practices in the respects of wastewater treatment mentioned in indicator 4.10.1, Apple has taken Flexium’s best practices as case studies and integrated them into the Apple’s Supplier Responsibility Report in 2017 and the Highlights of Outstanding EHS Projects and Tips of Apple’s Supplier in 2017 to spread Flexium’s best practices in Apple’s suppliers.
REF079: Apple’s Supplier Responsibility Report in 2017
REF080: Highlights of Outstanding EHS Projects and Tips of Apple’s Supplier in 2017
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4.18.1 List actions taken in the context of WASH (5 points)
Flexium has established a “Flexium Warm Heart Fund”. By using this fund, Flexium provides bottled water and other foodstuff to local fire brigade every year. Flexium also provides water-related training to local primary schools to enhance the children’s knowledge of drinking water safety and their awareness of protecting water environment and saving water. Relevant records, photos and videos were reviewed during site visit.
REF038: Pictures for providing bottled drinking water for local fire brigade
REF081: Pictures of implementing water-related education programme in local school
REF082: Video of implementing water-related education programme in local school
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5 Evaluation “against the actions taken in the implementation of the plan”
5.5.1 Review of the site water stewardship performance with executive team or board and provide evidence of meeting through minutes
Flexium has established an AWS executive team that is responsible for evaluating the site water stewardship performance. The factory manager is the team leader, and the team members consist of all department managers. A management meeting regarding water stewardship was held on 5 September 2018. Through the management meeting, Flexium identified water resources challenges in the catchment, water risks and water-related opportunities. A documented water stewardship plan in 2018 was developed. In addition, a water stewardship training was provided to employees on 7 September 2018.
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REF068: Review Report of Water Stewardship in 2018
REF069: Attendee list of water stewardship review meeting
REF073: Attendance list for training of water stewardship
REF074: On-site traing pictures
REF075: Flexium water stewardship training materials
6 Disclosure and communication of performance
6.7.1 Evidence of implementation of a programme for water education at catchment level and description of the programme
Flexium has organized and implemented a water-related education programme in local schools aiming to promote water-related knowledge and raise students’ awareness of water conservation. Tips of saving water in daily life were lectured to students. Related documents and pictures were kept by Flexium.
REF081: Pictures of implementing water-related education programme in local school
REF082: Video of implementing water-related education programme in local school
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Total 56
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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. The following 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 Flexium Relevant References
1 Minor Non-Conformance
01MINCAR Indicator 2.3.1 Catchment data (catchment plan, public initiatives and/or public goals for the site).
Flexium has established an update list of catchment plans, scenarios and notifications has been established which consists of 6 national-level catchment plans, 4 provincial-level catchment plans and 15 Kunshan City-level catchment plans. However, no aspects of the catchment plans related to Flexium’s water stewardship were identified.
On 8 December 2018, Flexium provided a corrective action plan for 01MINCAR, which consisted of:
Root analysis: because of insufficient understanding of the AWS standard requirement, only the catchment plans, scenarios and notifications were collected without identifying relevant articles.
Corrective actions: identify relevant articles of the catchment plans, scenarios and notifications, and take the relevant requirements into full consideration when developing the company’s water stewardship targets in the future.
Responsible person: Xunrong Huang, Safety & Environmental Protection Department
Implementation deadline:31 May 2019. Based on our review, the corrective action plan is acceptable.
REF014: Response to Finding 01MINCAR
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No. Type Ref. Details Response by Flexium Relevant References
2 Minor Non-Conformance
02MINCAR Indicator 2.3.2 Water governance for the catchment: Water legal and regulatory requirements, including water and water use rights
Flexium has established an update list of water-related laws and regulations. However, no relevant articles of national and local water-related laws and regulations that are applicable to Flexium’s water stewardship have been identified.
On 8 December 2018, Flexium provided a corrective action plan for 01MINCAR, which consisted of:
Root analysis: because of insufficient understanding of the AWS standard requirement, only the water-related laws and regulations were collected without identifying relevant articles.
Corrective actions: identify relevant articles of the water-related laws and regulations, and update the related information at least once a year.
Responsible person: Bo Cao, Safety & Environmental Protection Department
Implementation deadline: 30 June 2019.
Based on our review, the corrective action plan is acceptable.
REF016: Response to Finding 02MINCAR
3 Minor Non-Conformance
03MINCAR Indicator 2.5.2 Indirect water use: list of outsourced services that consume or affect water quality. List estimated annual withdrawals and quality data.
Flexium has collected the indirect water use and wastewater discharge of its main suppliers of raw materials and customers. However, no test report of wastewater discharge is collected by Flexium regarding its main suppliers of raw materials and customers.
On 8 December 2018, Flexium provided a corrective action plan for 01MINCAR, which consisted of:
Root analysis: because of insufficient understanding of the AWS standard requirement, only the indirect water use and wastewater discharge of main
REF040: Response to Finding 03MINCAR
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No. Type Ref. Details Response by Flexium Relevant References
suppliers were collected without collecting their water quality data.
Corrective actions: Further collect the water quality data of main suppliers, and conduct statistics and analysis.
Responsible person: Yunfang Xia, Purchasing Department
Implementation deadline: 31 March 2018.
Based on our review, the corrective action plan is acceptable.
4 Minor Non-Conformance
04MINCAR Indicator 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
At present, water quality monitoring sections have been established for main rivers by the national and local environmental protection authorities in the catachment. If the deterioration of water quality at the river sections is monitored, the national or local environmental protection authorities will launch their emergency response plans, which may result in the production restriction, suspension or even shutdown of a factory in the catachment to reduce effluent discharge. However, Flexium fails to evaluate this water related emergencies and develop its response plan.
On 8 December 2018, Flexium provided a corrective action plan for 01MINCAR, which consisted of:
Root analysis:failed to integrate the government authorties’ emergency measures into the company’s emergency response plan.
Corrective actions: Fully analyse the water related emergencies, develop relevant response plan and integrate the plan into the company’s wastewater management procedure (PU4602).
Responsible person: Jason Zhang, Safety & Environmental Protection Department
REF070: Response to Finding 04MINCAR
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No. Type Ref. Details Response by Flexium Relevant References
Implementation deadline: 31 March 2019.
Based on our review, the corrective action plan is acceptable.
5 Minor Non-Conformance
05MINCAR Indicator 5.3.1 Feedback and commentaries from stakeholders on the site water stewardship performance and factor input in the updated action plan
Flexium conducted a satisfaction survey regarding its water stewardship in September 2018, and relevant stakeholders including employees, local residents, suppliers and customers were involved. However, no summarized analysis was conducted regarding the stakeholders’ feedback.
On 8 December 2018, Flexium provided a corrective action plan for 01MINCAR, which consisted of:
Root analysis: because of insufficient understanding of the AWS standard requirement, although a satisfaction survey was performed, no summarized analysis was conducted.
Corrective actions: Conduct a satisfaction survey on a yearly basis, analyse the stakeholders’ feedback, and consider their inputs when updating the company’s action plan.