IETP is passionate about toys and the people who make them. We work with the toy supply chain to build better lives for workers and a stronger industry through the ethical production of toys. ICTI Ethical Toy Program Program Updates 5 Oct, 2018
IETP is passionate about toys and the people who make them. We work with the toy supply chain to build better lives for workers and a stronger industry through the ethical production of toys.
ICTI Ethical Toy Program
Program Updates 5 Oct, 2018
• This training is aimed to interpret IETP requirements. While every endeavor has been made to ensure the accuracy of the information in this training, IETP will not accept any responsibility for any loss or consequence howsoever caused by any reliance placed on such information.
• The provisions of this IETP constitute minimum and not maximum standards. The interpretation in this training shall not be used to prevent international labor standards or national and/or local laws and regulations from being exceeded.
Disclaimer
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Ethical Toy Program 2017
factories in the program
1,100+ workers covered
630,000+
Countries & regions
12
factory-brand links in Connect Platform
3,000+
14 year’s experience
China Vietnam Thailand Indonesia India Malaysia
Sri Lanka Taiwan Tunisia
Korea Singapore
Japan
Certified factories:
Countries for future expansion of the program:
Mexico Czech Republic
Myanmar Brazil
Where we operate
Our offices:
Hong Kong SAR, China, India, UK & USA
Buyer membership
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Save time with all your suppliers audit data in one place
Mitigate risk with advanced monitoring and real time updates the moment anything changes at your supplier
Pledge your support to raise ethical standards and improve the lives of workers in the toy industry supply chain and have your commitment publically recognized
Pre-screen potential suppliers with access to our database
Tools and support you need
Tackle root causes using our expert special investigation team, working on-the-ground to solve problems and engaging factory management (incident report)
Strengthen stakeholder engagement, with support on how to address the increasing requests from NGOs, investors, and the media
Instant Access to Status, Audit Reports, CAPs & notification, increasing the efficiency of your compliance program with the Connect Platform
Monitor, manage and improve the ethical performance of your manufacturers + look for potential ones with our online platform
Build capability with support programs to increase ethical knowledge, skills, and commitment amongst those you source from
Benefits for brands & retailers
Global community of Ethical Toy Program Members …
Some of the Retailers we work with…
1. PA to PV
2. Changes to Certification
3. Implementation
4. Updates to the Audit Checklist
5. New Checkpoints to the Audit Checklist
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Agenda
to the Audit Checklist 6. On-Site Corrections 7. Preparation for Changes 8. Audit Report Formats 9. Factory Programs
1. PA to PV Progress Audit (PA) will be replaced with Progress Visit (PV) 2. New Certification Status Added a new status – Progressing. 3. Policy updates 5/6 day work week – 40 hours / 6+ working days in China is not accepted by IETP effective Jan 1,19 4. Enhanced Audit Checklist
a) Clearer categorization (14 sections) and requirements – simpler and more accessible; b) Introduced non-compliance rating – zero tolerance, critical, major, minor c) Reduced allowable working hours to 72 hours standard d) New checkpoints
5. On-Site Corrections 6. Remediation Actions Recommendation Based on factory’s input client list, IETP may recommend different remediation (FU/DR) differ from IETP normal practice
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Program Change Highlights
1. From Progress Audit (PA) to Progress Visit (PV)
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IETP – Certification Flow
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Old
IETP – Certification Flow
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New
Factory is always suggested to apply for IAA 135 days prior to existing certification expiry.
Progress Audit (existing)
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Time 2-6 months after Seal issued
(All factories) 2-4 months after Certified (All factories)
Type Unannounced audit Announced 2-way visit Sr. mgt. involvement mandatory
Checklist: Working hours, wages, selected EHS Scope
Checklist: Working hours, wages, selected EHS “Best practices” or “nice to have” items Open discussion, Q&A
Conducted by Accredited auditor from 1 of 4 accredited
audit firm
IETP accredited visitors IETP staffs
Possible outcomes
Termination (zero tolerance) Probation Seal (maintain, up-/down-grade)
Termination (zero tolerance) Certification (maintain) Submit CAP for remediation and records
Progress Visit (new)
How will factories be affected? What we want to achieve with factory in PV
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This is NOT AN AUDIT
1. Encourage transparency, open communication and discussion
2. Top, senior management engagement, commitment
3. Status update to factory compliance level
4. Sustainability to current certification
5. Support for future assessments
6. Improvement opportunities via enhanced Root Cause Analysis
7. Practices sharing among industry
8. Determine future training, support opportunities
Progress Visit - Routine
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How will factories be affected?
1. Pre-engagement prior to visit , seeking for factory's concerns and questions. 2. Q&A on factory’s inquiries. 3. Review wages, compensations for systematic improvement opportunities. 4. Factory tour for potential and high-risk EHS areas. 5. Root Cause Analysis and discussions for CAP preparation
• IETP requirements, (On-site CAP required for closure monitoring) • Observations (CAP recommended)
6. On-site CAP posted on Connect for monitoring and update.
Enhanced Root Cause Analysis- Typical CAP received
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Item 条款
PV Finding 违反项目 Cause of Non-Compliance 违反原因
Corrective Action Plan and Completion Date 整改计划和完成日期
Preventive Action and Completion Date 预防措施和日期
Audit Finding and CAP
Evacuation aisle at the warehouse and assembly workshop was partially blocked by materials.
It was caused by workers' carelessness
During audit date, the findings had been corrected before auditor leaving and all materials had been moved. Completion Date: Immediately
The factory will assign a safety officer or security guard to inspect all major areas including evacuation aisles on a regular basis. Completion Date: Immediately
Evacuation aisle partially blocked
Worker’s carelessness
Regular inspections
Removed immediately
Item 条款
PV Finding 违反项目 Cause of Non-Compliance 违反原因
Corrective Action Plan and Completion Date 整改计划和完成日期
Preventive Action and Completion Date 预防措施和日期
PV Finding and CAP
Several secondary evacuation aisles were partially blocked by materials.
1.The factory did not have a comprehensive evaluation to the layout on the fire safety before moving machines and work stations into the workshop 2.When placed new machines or new production lines, the fire safety conditions were not re-considered.
1.Immediate remove all materials that caused blockage. 2.Redesign the layout of workshops base on fire safety requirement, and the passage between each work station and aisle is reasonable. Completion Date: within 10 working day
1.Relocation of any work stations/machines must follow the fire safety requirements. 2.Any changes to the layout in future must be approved by EHS officer before implementing and monitored during implementing. 3.Assign a safety officer to conduct regular inspection after redesigning to ensure all aisles and work stations are kept clearly in case of emergency evacuation. Completion Date: within 10 working day
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Evacuation aisle partially blocked
1. Lack revisit and consultation with EHS for layout change
1. Layout Change SOP update , enforcement
2. EHS involvement and approval 3. Regular Inspections
1. Removed immediately
2. Layout, fixture re-design
Enhanced Root Cause Analysis- Example CAP received from PV
Practices Sharing
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2. Changes to the Certification
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Current ICA/IAA process
Seal A60 Seal A Seal B Seal C
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IAA/ICA
Desktop
Follow-up
Existing
Full Compliance
NC Remediation
Audit Status: Audited Seal
Certified
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New
New ICA/IAA process
Audit Status: Assessed Certified
IAA/ICA
Desktop
Follow-up
NC Remediation
Full Compliance
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Seals are no longer determined only by weekly working hours
A pioneering, objective, comprehensive way to assess
factories’ social responsibility
Highlights of the changes
All procedures and timeframes remain unchanged
Time needed to get certified remains unchanged
Terms for probation and termination remain unchanged
Correction actions needed post-audit remain unchanged
Follow-Up & Desktop Review mostly remain unchanged – we work to
strike a balance within the industry, helping factories meet the
requirements of most buyers to avoid duplicated audits
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Highlights of the changes Highlights of the changes
Certified
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New
Introduce another audit status - Progressing
Audit Status: Progressing
IAA/ICA
Desktop
Follow-up
NC Remediation
Full Compliance
Certified
No Critical violations
Less than 30% Major violations in each section
Accepted CAP
Progressing • A status in the system • Not Certification • Valid for 6 months from audit date • Factory will become Certified when
achieve Full Compliance
A ‘Progressing’ factory means
no critical NC
moving to Certification in a short period of time (e.g. remediation timeline on Major/Minor is typically 2 months or less)
limited Major findings, with acceptable CAP submitted
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For a ‘Progressing’ factory, consider
• earlier engagement with these factories?
• conditional PO placement?
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3. Implementation
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Checklist V2.0 with minor updates Replace PA with PV Launch new Audit Checklist
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Before Oct 15
1st October
1st November
Arrangement at Launch
1. IAA/ICA:
a)Audits conducted on or after 1st November will be using the new Audit Checklist.
b)If an audit is previously conducted before 1st November and follow-up is needed, the follow-up audits will still use the existing Audit Checklist.
31 2018 ICTI Ethical Toy Program. All rights reserved. No unauthorized reproduction.
4. Updates to the Audit Checklist
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Changes made to the Audit Checklist
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1. Clearer guidance: the checkpoints are now grouped into relevant sections, more logical and easier to understand
2. Non-compliance are now graded to show its severity:(Zero Tolerance/Critical/Major new /Minor new), less severe non-compliance will be identify as Major or Minor
3. Adjusted the weekly working hours: reducing upper limits to 72 hours per week 4. Added checkpoints (Total 270 from current 205)
1. New Requirements - 27 2. Existing requirements to new checklist - 4 3. Current checkpoints expansion - 34
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1 Audit Process (4) 3 Employment Practices (15) 4 Special Protections (5)
1.1Transparency (2) 3.1 Policy (2) 4.1 Young Workers (2)
1.2Interference (2) 3.2 Training (1) 4.2 Pregnant Workers (3)
3.3 Underage Workers (2)
2. Business Ethics 3.4 Documentation (2) 5 Working Hours (11)
2.1 Policy (2) 3.5 Contracts (3) 5.1 Policy (2)
2.2 Training (1) 3.6 Homework and Cottage Work (1) 5.2 Documentation (3)
3.7 Recruitment Fees (2) 5.3 Working Hours (1)
3.8 Foreign Migrant Workers (2) 5.4 Breaks (5)
Sections of the New Audit Checklist
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6 Compensation (13) 8.2 Training (1)
6.1 Policy (2) 8.3 Implementation (9) 6.2 Wages and Benefits (3) 8.4 Human Trafficking (1) 6.3 Withholdings and Deductions (5) 6.4 Payroll and Pay slips (3) 9 Discrimination (4)
9.1 Policy (2) 7 Disciplinary Practices (9) 9.2 Implementation (1) 7.1 Policy (2) 9.3 Reporting Mechanism (1) 7.2 Training (1) 7.3 Implementation (6) 10 Grievance Mechanisms (12) 10.1 Policy (2) 8 Forced and Prison Labor (13) 10.2 Employee Representation (7) 8.1 Policy (2) 10.3 Freedom of Association (1)
10.4 Worker Helpline (2)
Sections of the New Audit Checklist
11 Facilities (29) 12 Fire and Emergency (46) 11.1 Policy (2) 12.1 Policy (3) 11.2 Emergency Communication (1) 12.2 Emergency Response Personnel (1) 11.3 Factory Security (2) 12.3 Fire Acceptance Certificate (1) 11.4 Building Safety (2) 12.4 Exit and Evacuation (8) 11.5 Housekeeping (5) 12.5 Fire Fighting System (10) 11.6 Working Conditions (5) 12.6 Alert System (3) 11.7 Drinking Water (2) 12.7 Emergency Drills (2) 11.8 Sanitation (3) 12.8 Electrics (4) 11.9 Medical Safeguards (5) 12.9 Flammable and Combustible Hazards (9) 11.10 Vehicles (2) 12.10 Smoking Rules (2)
12.11 Lightning Protection (1) 12.12 Emergency Investigation and Reporting (2)
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Sections of the New Audit Checklist
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13 Environmental, Health and Safety (EHS) (70) 13.10 Chemical Safety (12) 13.1 EHS Program (3) 13.11 Incident Investigation and Reporting (4) 13.2 Training (2) 13.12 Environmental (9) 13.3 EHS Committee (3) 13.4 Occupational Health (4) 14 Dormitory and Canteen (36) 13.5 Personal Protective Equipment (PPE) (5) 14.1 Facility (10) 13.6 Workplace Safety (7) 14.2 Emergency Preparedness Policy (3) 13.7 Machinery Safety (9) 14.3 Exit and Evacuation (7) 13.8 Equipment Safety (6) 14.4 Fire Fighting System (8) 13.9 Hot-Work and Gas Cylinders (6) 14.5 Emergency Alert System (3)
14.6 Canteen (5)
Sections of the New Audit Checklist
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Non-Compliance Current Checklist New Checklist
• Forced Labor • Child Labor • Access Deny • Bribery Attempt
Zero Tolerance Termination
• IAA – Record Inconsistency, on-site transparent
• Inaccurate Overtime payment • Working Hours • Serious Safety Issue
Critical, No Seal,
Remediation Needed
Comparison: Current & New Checklist
Zero Tolerance Termination
Probation Probation
Critical, No certification,
Remediation Needed
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Non-Compliance Current Checklist New Checklist
Comparison: Current & New Checklist
• Did not provide EHS training to workers
• Did not conduct regular inspection and test
• Lack of written policy of the training for the security guard
No Certification, Remediation Needed
* Major Status: Progressing No Certification, Remediation Needed
No Certification, Remediation Needed
* Minor Status: Progressing No Certification, Remediation Needed
How to read the New Checklist?
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Checkpoint no.
Checkpoint Question Compliance Guidance Text
5.2 Documentation
5.2.2 Are all hours worked documented? > 20% sampled records
are incomplete of with errors
Yes
Critical
Major
N/A
≤ 20% sampled records are incomplete of with errors
1. Example of acceptable time records: a. Time clock system ( worker’s signature
confirmation is needed once per month), b. Piece rare records (worker’s signature
confirmation is needed once per month), c. Manual time recording system (worker’s
signature confirmation is needed once per week(, or
d. Computer recording system. 2. Time records must be completed and include, but are not limited to: a. Information about the worker, and b. Signature confirmation where required. 3. Time records must be provided for the required audit period (e.g.: 12 months) 4. Time records must cover all workers in the factory
Current Checklist 2.7, 2.8 Case Study
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New Audit Checklist -5.4 Breaks Case Study Checkpoint
no. Checklist Question Compliance Level
5.4.1 Do workers receive 1 day off in a pre-defined week?
Yes Critical
Major
N/A
> 20% of sampled workers are not given day off/ 1 samples
worker has worked more than 13 days consecutively ≤ 20% of sampled workers are not given the day off
5.4.2 Do workers receive meal breaks of at least 20 minutes?
Yes Critical
Major N/A
> 20% of samples workers do not receive such breaks ≤ 20% of sampled workers do not receive such breaks
5.4.3 Do workers receive breaks of at least 15 minutes after 6 consecutive hours worked?
Yes Critical Major N/A
> 20% of samples workers do not receive such breaks ≤ 20% of sampled workers do not receive such breaks
5.4.4 Are workers provided with at least 10 consecutive hour rest in a predefined 24-hour cycle?
Yes Critical
Major N/A
> 20% of sampled workers are not provided with such rest/ 1
samples worker has less than 8 hours rest ≤ 20% of sampled workers are not provided with such rest
5.4.5 Are workers allowed toilet and water breaks?
Yes Critical Major N/A
> 20% of samples workers are restricted in taking these breaks ≤ 20%of samples workers are restricted in taking these breaks
Current Checkpoint 2.7, 2.8 to New Checkpoint 5.4.1 – 5.4.5, an expansion of 3 checkpoints
Scenario Current Checklist New Checklist
1) 5 out of 20 workers didn’t receive 1 day off in a pre-defined week?
NC to 2.7 Status: Audited No Seal. – Seal will be issued after remediation
Critical to 5.4.1 Status: Accessed No Cert. – Cert. will be issued after remediation
2) 2 out of 20 workers were working for 6 consecutive hours without 15 mins break
NC to 2.8 Status: Audited No Seal. – Seal will be issued after remediation
Major to 5.4.3 Status: Progressing No Cert. – Cert. will be issued after remediation
3) 1 worker did not receive 30 mins lunch break
NC to 2.8 Status: Audited No Seal. – Seal will be issued after remediation
Major to 5.4.2 Status: Progressing No Cert. – Cert. will be issued after remediation
• Same process for the Remediation • Guidance text for non-compliance is clearer
• More specific on the areas of improvement needed
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5. New Checkpoints
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Major Changes of New Checklist
45
Added checkpoints (Total 270 from current 205)
1. New Requirements - 27 2. Existing requirements to new checklist - 4 3. Current checkpoints expansion – 34
2018 ICTI Ethical Toy Program. All rights reserved. No unauthorized reproduction.
2018 ICTI Ethical Toy Program. All rights reserved. No unauthorized reproduction.
Major Changes of New Checklist
2018 ICTI Ethical Toy Program. All rights reserved. No unauthorized reproduction.
Section CP No. Checkpoints Grading
Audit Process
1.1.1 Has the factory allowed the audit to be conducted without denial of access? ZT 1
1.1.2 Has the factory allowed the audit to be conducted without intentional concealment or hidden audit scope?
ZT 2
1.2.1 Is the whole assessment process free from bribery attempts? ZT 3
1.2.2 Is the coaching of workers prohibited? Critical 4
Business
Ethics
2.1.1 Does the factory have a Business Integrity policy? Minor 5
2.1.2 Is there a designated staff member responsible for implementing the Business
Integrity policy?
Minor 6
2.2.1 Are supervisory staff, who may be exposed to unethical behavior, trained on the
Business Integrity policy?
Minor 7
Employment
Practices
3.3.2 The factory has no cases of historical underage workers? Major 8
3.7.1 Does the factory have a policy which prohibits charging recruitment fees to workers? Minor 9
3.7.2 Has the factory verified that recruitment brokers and agents used adhere to legal hiring
practices?
Major 10
3.8.1 Does the employment of foreign migrant workers comply with legal requirements? ZT 11
3.8.2 Does the factory prohibit charging foreign migrant workers recruitment related fees? Major 12
New IETP Requirement
Existing added to checklist
Major Changes of New Checklist
47
Section CP No. Checkpoints Grading
Special
Protection
4.2.1 Are pregnant workers assigned appropriate job tasks? Major 13
4.2.2 Are pregnant workers given additional necessary and reasonable breaks? Major 14
4.2.3 Are female workers with breastfeeding needs provided with appropriate space and
breaks?
Major 15
Working Hours 5.3.1 Are maximum weekly working hours within IETP requirements? Are maximum weekly working hours within IETP requirements? > 78hrs / week,Critical; 72hrs< WH≤ 78hrs,Major
Critical
Major
16
Compensation 6.3.1 Does the factory have a written policy for replacement items in the case of loss or
damage by workers?
Minor 17
Forced and Prison Labor
8.4.1 Is human trafficking activity prohibited? ZT 18
Grievance Mechanisms
10.3.1 Are union activities free from unreasonable management intervention or punishment? Critical 19
10.4.2 Is it prohibited to modify the information on the Helpline Cards and Posters? ZT 20
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Major Changes of New Checklist
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Section CP No. Checkpoints Grading
Facilities
11.3.2 Are children prohibited from entering factory production areas and warehouses? ZT 21
11.6.5 Any citations or penalties for violations of laws on working conditions in the past 12 months have been reported to IETP within 48 hours?
Major 22
Fire &
Emergency
12.1.2 Does factory have a written fire prevention policy? Major 23
12.3.1 Does the factory have an official Fire Acceptance Certificate? Critical 24
12.4.1 Are emergency exits and evacuation paths built in line with legal requirements? Critical 25
12.6.2 Is the installed alarm system inspected and tested monthly? Major 26
12.7.2 Does the factory plan additional fire drills where required? Major 27
12.12.2 Are major factory incidents and emergencies reported to IETP within 48 hours? Major 28
EHS 13.4.1 Are occupational health checks provided to applicable workers? Major 29
Dorm &
Canteen
14.1.6 Are dormitories kept clean and maintained in good condition? Major 30
14.2.2 Does dormitory have a written fire prevention policy? Major 31
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6. On-Site Corrections
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On-Site Corrections
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How will factories be affected?
1. Identify occasional errors, mistakes in selected areas
2. Immediate correction 3. CAP for system enhancement 4. Record in Remarks in audit report 5. Systematic issues will not be considered
On-Site Correction Examples
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7. Preparation for Changes
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How will factories be affected? Buyers Preparation
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1. Understand there are no changes to the Audit Process, timeline, remediation standards
2. Review the Checklist 3. Determine engagement policy with factories with audit status
“Progressing”
4. IETP will have one full audit report annually (IAA/ICA). PA report
will now be replaced with a PV on-site CAP
8. Audit Reports Formats
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9. Factory Programs
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Family-Friendly Spaces (FFS)
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Summer program to reunite migrant workers with their left-behind children
• Allowing children to connect with their parents during summer school breaks
• Strengthening the parent-child link that lies at the heart of the toy industry
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2016
2017
2018
2 factories implemented a pilot program.
18 factories joined FFS program, 9 of them implemented again.
11 factories joined FFS program, 2 of them implemented again.
500 Children 691 Children 85 Children
Family-Friendly Spaces (FFS)
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Q&A