Sustainable Apparel

Coalition
SAC Higg FEM Verification
Quality Assurance Manual
Version 1.0

Issued: April 2020

Sustainable Apparel Coalition
PO BOX 237
San Francisco, CA 94104
Contents

Introduction ................................................................................................................................... 3
1. QA Activities Overview........................................................................................................... 4
2. Quality Assurance (QA) Procedures ...................................................................................... 7
A. Verifier Body and Verifier Selection Process 7
B. Assessing Verifier Bodies’ (VB) Internal Management Systems 10
C. Desktop Review (DR) 11
D. Counter Verification (CV) 13
E. Duplicate Verification (DV) 18
F. Shadow Verification (SV) 21
G. Feedback from Facilities 23
H. Disputes 24
I. Verifier Scoring 26
Appendices ..................................................................................................................................27
Appendix I – Extreme Cases (for Invalidating Reports) 27
Appendix II – List of Abbreviations 28

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Introduction
Sustainable Apparel Coalition is the apparel, footwear, and textile industry’s leading alliance for
sustainable production. The Coalition develops the Higg Index, a standardized suite of tools for
all industry participants to assess social and environmental value chain performance.

Among the suite of tools, the Higg Facility Environmental Module (Higg FEM) is a holistic self-
assessment tool that evaluates the environmental performance of facilities that produce textiles
and apparel. Upon completion of the self-assessment, facilities can choose to verify the
accuracy of their self-assessed results. The SAC approves Higg FEM Verifier Bodies (VB) and
Higg FEM Verifiers based on detailed criteria SAC members have aligned on through the
extensive member engagement process. More details about the Higg FEM Verification
Program can be found at https://howtohigg.org/higg-fem-verification-program/.

This Quality Assurance Manual describes the quality assurance (QA) activities that are applied by
the SAC Higg FEM Verification Program Manager (VPM). QA activities are designed to ensure a
qualified pool of SAC approved verifiers is available to Higg FEM users, and to ensure quality and
integrity during the Higg FEM verification process. It includes a description of the goals and
expected outcomes of QA processes and the specific procedures that define how the VPM
executes QA.

Higg FEM QA Goals

The purpose of Higg FEM QA is to provide high level oversight of Higg FEM Verification and to
evaluate whether the verification process is producing consistent and accurate outcomes as per
the related protocols and procedures, instead of focusing on the accuracy of particular
assessments (Note that QA is not focused on the accuracy of specific verified assessments).

QA Activities
In Q4 2019, the SAC conducted a QA pilot to better understand how each Higg FEM QA
activity works and to determine sample size for a 2020 roll out of Higg FEM verification. Based
on the learnings of this pilot, these QA activities were chosen for 2020:
A. Vetting and testing applicant verifiers and verifier bodies (VBs)
B. Assessing VBs’ internal management systems
C. Desktop Reviews
D. Counter Verifications
E. Duplicate Verifications
F. Shadow Verifications
G. Feedback from Facilities
H. Disputes
I. Verifier Scoring

The SAC determines the coverage (exact number of verifications to conduct) for each QA
activity, considering the cost and value of each activity. In determining how many times to
conduct activity, the SAC makes sure that QA ensures the quality of the Higg FEM verification
process and generating insights for overall system improvements.

For more details on sampling, please contact the SAC team.

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Reading guide
In the QA overview (section 1) all QA activities are described, in section 2 the specific
procedures are outlined for each activity.

1. QA Activities Overview
QA activity Why What
Vetting and Through vetting and • Assessing of candidate VBs and Verifiers against
testing of testing applicant Verifier SAC criteria (regarding their experience
Verifiers Bodies (VB) and Verifiers, conducting environmental assessments,
Verifier the VPM ensures that knowledge of legal requirements and
Bodies (VBs) requirements are met international standards and education) for the
regarding professional countries where they propose to operate
experience, internal • Mandatory taking of e-learning training course
quality management on Higg FEM verification program and
systems and auditing processes
• Exam to test candidate Verifiers on technical
skills and knowledge of
skills, and their knowledge of SAC procedures
SAC procedures and
and protocols
protocols
Assessment As it is the responsibility An assessment of the policies and procedures VBs
of VBs of VBs to ensure that have in place to ensure their Higg FEM Verifiers’
management Verifiers have the skills competency and consistency of Verification
systems and experience required activities.
to perform Higg FEM
Verifications, these
assessments help ensure
that VBs have the
management system in
place to ensure quality
and integrity of their
verifiers
Desktop Desktop Reviews are an A Desktop Review is a remote assessment of
Review effective method of verified reports. A Desktop Review assesses report
ensuring that verifiers are content, with a focus on instances where the
completing verification Verifier has provided a corrected response.
reports correctly and that
data in reports is accurate. A Desktop Review identifies any issues in the report,
They are also used to including:
identify aspects of the ● Whether approved and qualified verifiers
SAC system that are not completed the verification
well understood by ● Corrected responses that are inaccurate
verifiers. ● Instances where a facility provides
inconsistent information that is not
corrected by the verifier
● Any instances where it appears that the
question was misunderstood by the verifier,
causing the “corrected response” to be
misleading

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 ● Misapplication or misinterpretation of local
laws

Desktop Reviews check for any issues that could

cause the report to be invalidated

Desktop reviews assess the verification procedure

as follows:
● The report captures any instances where
Verification procedure was not followed
including:
● Proper completion of the online verified
Higg FEM
● Number of days spent on site is less than
SAC recommendations
Counter Counter verifications Counter Verifications are 1-day visits to facilities that
Verification provide insight into were recently visited for a Higg FEM verification.
whether the Higg FEM Counter Verifications assess whether verification
verification process is procedures were followed, if Verifiers had the skills
producing accurate and and knowledge to conduct the verification, and if
reliable data report content is accurate.

Counter Verifications are not a duplication of the

initial verification, rather a high-level verification
including a sample of all sections of the Higg FEM.
Duplicate By repeating an entire Duplicate Verifications are a repeat of a Higg FEM
Verification assessment at a different verification, performed by a different VB or the VPM
point in time, Duplicate after the initial verification. Similar to Counter
Verifications assess Verifications, Duplicate Verifications employ the
whether verification same methods of verifying information used in
procedures were Verifications (e.g. management interviews,
followed, if verifiers had document reviews). Differences are analyzed and a
the skills and knowledge determination of the reasons for discrepancy is
to conduct the made. The determination of why there are
verification, and if report discrepancies is essential to determining whether
content is accurate verification procedures were followed, whether
verifier conduct was in line with SAC procedures,
etc.
Shadow Shadow Verifications are During Shadow Verifications the VPM or designated
Verification used to assess verifier representative observes a verification to ensure that
quality and identify areas the verifier follows SAC protocols. Through direct
where SAC protocols are observation, the VPM can confirm whether verifiers
not clear or not well are following SAC requirements when conducting a
understood by verifiers. verification. During a Shadow Verification, the
shadow verifier does not actively participate in the
assessment.
Feedback Feedback will be Feedback is reviewed through feedback forms that
from collected from facilities are to be filled by a facility after every verification.
Facilities to assess the functioning
of verification process in

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 general, as well as
verifiers and VBs.
Disputes Disputes allow facilities to On the higg.org platform, a facility raises a dispute if
formally raise concerns a verifier did not follow Verification Protocol or
over the quality of a other SAC requirements were not met. The VPM
verification and for the determines whether the dispute is valid and if the
VPM to determine if this verified assessment report needs to be amended.
resulted in an impact to Disputes are not used to resolve question level
the accuracy of the issues.
verified assessment
report.
Verifier Through verifier scoring, QA activities result in data regarding Verifier
Scoring the VPM can identify performance. Verifier scoring uses this data to rate
trends associated with Verifiers on all their overall quality. Data from
positive verifier application, testing, Desktop Reviews, on-site QA
performance and reviews (Counter Verifications, Duplicate
determine if there are Verifications, Shadow Verifications), and feedback
poor performing verifiers surveys all feed into Verifier scoring.
that need to be removed
from the system. Verifier
scoring can also be used
to incentivize timeliness
and professionalism.

Quality Assurance Outcomes

The QA activities that the VPM executes are selected to work together systemically to ensure
quality, identify issues, and improve the Higg FEM verification process and system as a whole. QA
methodologies such as Desktop Reviews, Counter Verifications, Shadow Verifications, and Duplicate
Verification are designed to detect issues with the verification process. The VPM uses a dashboard
to monitor QA activities, including the specific issues that are identified during each instance of QA.
On an ongoing basis, the VPM reviews and analyses these issues. The outcome of this analysis is a
determination if the issues detected during QA are systemic problems with the verification process
(e.g. Verification Protocol does not address a topic), issues with a particular VB or region (e.g. local
laws being interpreted incorrectly), or issues isolated to a particular verifier. In order to address
systemic issues, the VPM recommends revisions to the How To Higg Guide, howtohigg.org platform
training, Verifier qualifications, etc. Regional issues or VB specific issues may be addressed through
technical bulletins to verifiers or direct follow-up with VBs. In this way, QA helps to ensure that
problems with the verification process are not only detected but fixed in a systemic way. If a specific
QA activity indicates poor performance, or other issues with the verification process it can also
trigger additional QA. For example, if a Desktop Review shows that a Verifier has not gathered
sufficient evidence, this may trigger additional activities, such as a Shadow Verification, where the
verifier is observed on site.

Quality Assurance Communications

In addition to any reporting identified in the specific procedures below, the VPM consolidates the
QA outcomes and provides visual summaries via an updated dashboard for review by the SAC. For
example, the dashboard may display a chart that shows the overall rating of quality of reports
determined by Desktop Reviews by country or VB. The purpose of the dashboard is to provide real-
time access to QA outcomes and results so that the SAC can consider potential improvements to
the system and plan appropriately.

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2. Quality Assurance (QA) Procedures
A. Verifier Body and Verifier Selection Process
The VB/Verifier selection process ensures that VBs/Verifiers have the experience, skills,
knowledge, and quality assurance programs required to conduct consistent and reliable Higg
FEM verifications. This procedure defines how the VPM selects and approves VBs and Higg FEM
Verifiers.

Procedure

1. Verifier Body Application process

1.1 All verifiers must be employed by an approved Verifier Body.
1.2 Using an online application, VBs provide information regarding their company including
auditing/assessment experience, accreditations, management system and quality
control procedures.
1.3 The full list of requirements for VBs can be found the VPM (Sumerra) website:
https://www.sumerra.com/programs/sac/sac-fem-verification-program/

2. VB Selection process
2.1 Candidate VBs who meet the criteria are approved as Higg FEM VBs and can then have
individual verifiers associated with their organization apply to become Verifiers using the
process outlined below (Section 3).
2.2 All approved VBs are subject to review to ensure that VBs uphold their commitments to
develop policies and procedures on Higg FEM Verifier competence, training and internal
quality management

3. Verifier Application process

3.1 Using an online application, candidate verifiers provide information regarding their skills,
knowledge and experience.
3.2 The full list of requirements for candidate verifiers must meet for both General and
Chemical Specialist Verifier can be found the VPM (Sumerra) website here:
https://www.sumerra.com/programs/sac/sac-fem-verification-program/

4. Selection process
4.1 Candidate verifiers who meet the criteria take the required training. Training is delivered
online.
4.2 Once training is complete, Higg FEM Verifier candidates must take an exam.
4.3 Only Verifiers who have completed the training and passed the exam are eligible for Higg
FEM Verifier Status.

5. Maintaining Verifier status

5.1 Status is maintained by participating in Verifier Status Maintenance (VSM) program.
Details on the VSM program can be found on the VPM (Sumerra) website:
https://www.sumerra.com/sac/verifier-status-maintenance-program/

6. Verifier Application Audits

6.1 Application Selection and Requesting Information
6.1.1 The VPM periodically selects applications for auditing.

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 6.1.2 Applications are selected randomly as well as based on risk (applications that
appear to have unusual or inconsistent information).
6.1.3 Applications may be audited at any stage of the application and approval process
6.1.4 The VPM emails the applicant and request additional information and
documentation to support self-reported data in their application.
6.1.5 Applicants that are selected for an audit have at least 14 calendar days to provide
the requested information.
6.2 Review of Application Criteria
6.2.1 The audit focuses on self-reported data. Applicants are not required to provide
information that was included in the initial application.
6.2.2 Based on the information in the application, the VPM asks for one or more of
the following pieces of evidence to support the verifier application:
● Copies of selected audit reports to support audit log. Brand and other
identifying information is redacted as needed to meet confidentiality
requirements.
● Contact information for previous employers so they may be contacted to
confirm employment as noted.
● Contact information for reference(s) that can attest to work experience in
environmental sustainability/assessment.
● Copy of diploma, transcript, or other proof of post-secondary degree.
● Certificate of completion for all listed trainings.
● Documentation of receipt of internal training reported (e.g. sign-in sheets,
certificate, Learning Management System exports, etc.).
● English writing and speaking samples.

6.3 Review
6.3.1 The VPM completes the audit within 14 days of receiving information from the
applicant.
6.3.2 Additional information may be sought from the applicant based on their
responses.
6.3.3 If the applicant provides incorrect data/evidence, they have one additional
chance to provide correct data/evidence.
6.3.4 After performing the audit, the VPM determines whether the self-reported data
provided by the applicant is accurate.

6.4 Audit outcomes

6.4.1 If the self-reported data is generally accurate, no further action is needed.
6.4.1.1 Minor issues include honest mistakes in entering numbers/data, i.e. entering
incorrect data due to misunderstanding of question
6.4.2 If the self-reported data is not accurate, the VPM determines what impact the
inaccurate data has on the applicant’s application.
6.4.2.1 If the inaccurate data would have resulted in the applicant failing the initial
application, the applicant is suspended.
6.4.2.1.1 The auditor may formally appeal the suspension. The appeal will be
reviewed by the VPM and the SAC. The appeal decision is final.
6.4.2.1.2 The verifier may apply to be reinstated after 12 months.

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 6.4.2.1.3 The application must be approved by the VPM as well as the SAC.
6.4.2.2 If the inaccurate data would not have affected the initial application, the VB
is required to provide an explanation and corrective action plan to
demonstrate how it will ensure the accuracy of future applications.
Depending on the nature of the inaccurate data, the verifier may be
suspended.
6.4.3 Applicants are informed of audit outcomes.

Responsibilities
VPM: review applications and apply scoring; determine eligibility based on application score;
administer exam.
SAC: approves criteria

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 B. Assessing Verifier Bodies’ (VB) Internal Management Systems
Verifier Body Assessments review the policies and procedures VBs have in place to ensure the
quality of Higg FEM Verifications conducted by their verifiers. This procedure defines how the
Verification Program Manager (VPM) conducts VB assessments.

Procedure

1. Selecting VBs for assessment

1.1. All VBs will be subject to a management assessment. Both 2nd and 3rd-party VBs are
included.
1.2. Additional assessments may be conducted periodically and/or be based on VB
performance

2. Assessing Verifier Bodies

2.1. The scope of the assessment is the VB’s Higg FEM Verification program.
2.2. The VPM assesses:
● The VB’s policies and procedures on Verifier competence
● The VB’s policies and procedures on training for Verifiers
● The VB’s policies and procedures on internal quality, including report review
● The VB’s practices for calibrating Verifiers to ensure consistency, both within the VB
and with external requirements
● The VB’s practices for ensuring auditors act ethically
2.3. Assessments are conducted remotely. The VPM requests documentation from the VB
and may schedule teleconference meetings to review material with VB management.
Once the VPM requests documentation, VBs have 14 days to submit the requested
documentation to the VPM.

3. Reporting
3.1. The outcomes of VB assessments are recorded in a standard report form.
3.2. Outcomes of VB assessments are shared with VBs so they can take steps to address gaps
in their programs.

4. Corrective Action
4.1. If the VPM finds significant gaps in the VB’s program, the VB will be required to take
corrective action to address those gaps.
4.2. VBs that do not take corrective action may be subject to disqualification of their VB status
and the status of all associated verifiers.

Responsibilities
VPM: Select VBs for assessment in coordination with the SAC; ensure this procedure is
consistently followed; qualify staff as VB assessors.
VPM VB Assessor: Conduct VB assessment in line with this procedure and generate report.
SAC: Select VB’s for assessment in coordination with VPM.
VBs: Provide information and documentation, as requested by the VPM

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 C. Desktop Review (DR)
Desktop Reviews are remote assessments of verified reports. This procedure defines how
Desktop Reviews are conducted to ensure that they are the result of a high quality, reliable, and
consistent verification process.
Procedure
1. Report Selection
1.1. Reports are selected based on risk, through stratified random sampling and simple
random sampling. Approximately one-third of Desktop Reviews will be selected using
stratified random sampling, one-third selected based on risk and one-third using simple
random sampling. The strata for stratified sampling will include: country and VB. Note
that these ratios may be adjusted.
1.2. Desktop Review identifies any issues in the report, including
● Facility responses that were not verified
● Corrected responses that are inaccurate
● Instances where a facility provides inconsistent information that is not corrected by
the verifier
● Any instances where it appears that the question was misunderstood by the verifier,
causing the “corrected response” to be misleading
● Misapplication or misinterpretation of local laws
1.3. The risk factors for selecting reports for review may include specific quality assurance
flags identified by the SAC and VPM, VB/Verifier performance and facility feedback
surveys.
1.4. Depending on how many reports are flagged based on risk, not every flagged report
may be reviewed.

2. Report Review
2.1. Each facility response, verification selection (accurate, inaccurate, no response),
corrected response and verification comments, supporting documents are reviewed.
2.2. The report review identifies any instances where the report is incomplete or where
verified data is not supported with evidence including:
● Unclear language: English answer is interpretable in multiple ways, short answers
that do not do justice to the question.
● Facility responses that were not verified (No “Verification Response” selected).
● Corrected responses that are inaccurate (“Verification Comment” in the tool does not
support “corrected response”).
● Instances where facility provides inconsistent information that is not identified by the
verifier.
● Instances where it appears that the question was misinterpreted by the verifier,
causing “false positive” response.
● Misapplication or misinterpretation of local statuary requirements.
● Misapplication or misinterpretation of Higg FEM questions.
● Verification data supporting a corrected response is outside the scope of the
verification (prior year).

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 2.3. The report review also identifies any areas where the report was not completed correctly
and/or where the Verification protocol was not applied correctly, including:
● Corrected responses that do not include Verification comments with necessary
details.
● Report comments use auditing terminology (e.g. “auditor”, “auditee”, “non-
conformant”).
2.4. The VPM may contact the verifier for clarifying flagged issues.

3. Analyzing Inaccuracies and errors

3.1. Any inaccuracies and errors (as defined above) are analyzed as part of the Desktop
Review.
3.2. Inaccuracies and errors are categorized in order to summarize and report on the types
of inaccuracies and errors that are most common and most critical.

4. Reporting
4.1. Desktop Review outcomes are recorded in a standard report format.
4.2. Desktop Review reports are completed within 10 working days of selection of the report
review.
4.3. Information regarding Verifier performance is captured in the Verifier scorecard.
4.4. The VPM provides the SAC with a summary of issues identified through Desktop
Reviews.
4.5. Individual Desktop Review reports are not provided to VBs. The VPM aggregates
information on common mistakes and misunderstanding and may issue technical
bulletins to all VBs, so they are informed of common mistakes and critical issues. The
VPM may follow up directly with individual VBs if Desktop Review shows their verifiers
do not understand SAC protocols and the VB needs to take specific action to improve
their reports.

5. Invalidating Reports
5.1. If the Desktop review finds any of the issues listed in Appendix I, Extreme Cases, the VPM
may invalidate the Verification report.
5.2. If VPM determines a report must be invalidated, the VPM informs VBs and the facility
5.2.1. The VPM emails the facility and the VB informs that the report will be invalidated. A
short explanation of why the report is being invalided is provided.
5.2.2.Four calendar days after the facility and VB are informed, the VPM sets the report
status to Verification Invalidated (VRI) on the Higg.org
5.3. Instances where reports are invalidated due to errors or oversights by the verifier will be
captured in the Verifier scorecard. If a verification is invalidated due to significant issues
with verifier performance, the VPM may suspend the Verifier from conducting additional
verifications. Decisions to suspend Verifiers will be made jointly by the VPM and the SAC.

Responsibilities
VPM: ensure this procedure is consistently followed; select reports for review; qualify staff as
report reviewers.

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 D. Counter Verification (CV)
Counter Verifications are high level one-day visits to a recently verified facility. They are used to
assess whether Higg FEM Verification procedures are being followed, whether verifiers have the
skills and knowledge to conduct verifications, and whether verification report content is generally
accurate. Counter Verifications can also identify risk and identify ways to improve the overall
usability of the Higg.org system.

When inconsistencies in data are found a Counter Verification investigates further to assess
whether it is a competency issue (e.g. individual verifier’s knowledge and skills, training program),
a procedural issue (e.g. Verification Protocol quality, VB management procedures), or an ethical
issue (e.g. bribery, corruption).

This procedure defines how the VPM conducts Counter Verifications so that they produce
consistent and reliable feedback on the verification process.

Procedure

1. Counter Verification Selection

1.1. Counter Verifications are performed by qualified Counter Verifiers.
1.2. Counter Verifiers may work for either the VPM or a VB.
1.3. The VPM selects the Counter Verifier for each Counter Verification based on factors
including availability, experience and cost.
1.4. To be considered qualified a Counter Verifier must
● Meet the requirements for being a Verifier
● Have a minimum of 5 years’ experience conducting environmental assessments
and/or consulting work that covers all aspects included in the Higg FEM
● Have a minimum of 2 years’ experience conducting quality assurance such as report
reviews or internal audits
● Additional qualifications and experiences may be considered as equivalents for the
criteria listed above
1.5. A Counter Verifier cannot work for the VB that conducted the initial verification.

2. Counter Verification Facility Selection

2.1. All verified facilities are subject to Counter Verification.
2.2. Selection of facilities for Counter Verification is done jointly by the VPM and the SAC.
2.3. Facilities will be chosen based on several criteria including risk factors, size, facility type,
and geographic location.
2.4. The VPM contacts facilities to inform them of the Counter Verification.
2.5. Counter Verifications are announced. The VPM works with the facility and Counter
Verifier to find a suitable date for the Counter Verification.
2.6. There are no costs to facilities for Counter Verifications.

3. Counter Verification Preparation

3.1. Prior to the Counter Verification, the Counter Verifier reviews the verified report. This
allows the Counter Verifier to review any inconsistencies and determine which questions
to sample while on site. If the Counter Verification is conducted by a VB, the VPM makes

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 this information available to the VB/Counter Verifier at least two weeks prior to the
Counter Verification.
3.2. A Counter Verification agenda is sent to the facility at least one week prior to the Counter
Verification

4. Counter Verification Methodology

4.1. Counter Verifications take one working day.
4.2. Counter Verifications consist of three main activities:
1) Management interviews to assess verifier conduct and verification procedure during
the initial verification.
2) Review of assessment questions and verified responses. This activity will include
management/worker interviews, facility walk through, document review and other
activities that are part of a standard SAC verification.
3) Analyzing differences in verified assessment results and Counter Verification results.
4.3. These activities are conducted to assess the SAC verification process and determine
whether verification protocols are followed; whether verifiers have appropriate skills and
knowledge and if assessment reports are accurate and reliable. These activities are not
used to correct or adjust the outcomes of the initial Verification.

5. Counter Verification Process

5.1. Management interviews
5.1.1. There are two types of management interviews conducted during Counter
Verifications, each serving a different purpose. The first type of management
interview is to assess verifier conduct and Verification procedure during the initial
verification. This is an activity that is unique to Counter Verifications and the
purpose of this activity is to get input from facility management on the SAC
process. The second type of management interview is to assess report content.
This activity is similar to management interviews that take place during regular
verification and the purpose of this activity is to assess if the facility has accurately
answered questions.
5.1.2. To assess verifier conduct and verification procedure, a pre-defined set of
questions is used as a guide to interview management. Questions are formulated
to cross-check information from other QA activities and to gather additional
information.
5.1.3. Counter Verifiers should spend no more than one hour conducting management
interviews to assess verifier conduct and verification procedures.
5.1.4. Management interviews to assess the facility responses and corrected responses
to questions in the SAC tool follow the same procedure as during the initial
verification.

5.2. Reviewing assessment questions and verified responses

5.2.1. The purpose of assessing facility responses and corrected responses is to evaluate
if the verifier(s) marked questions correctly during the initial assessment. If this is
not the case an investigation starts into verifier quality and conduct (including an
investigation into bribery).

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 5.2.2. Report content is assessed by reviewing of a sample of facility responses and
corrected responses. The sample assesses questions from each Higg FEM section.
5.2.3. Prior to the Counter Verification, the counter verifier selects the questions that will
be sampled. Depending on actual conditions on site, the questions assessed may
be changed during the Counter Verification. The sample should include both
questions where the response was corrected and questions where the responses
were not corrected.
5.2.4. Counter Verifiers use the same Verification methodologies used during the initial
Verification and follow the SAC protocols for conducting verifications. Document
reviews, factory walk through, worker interviews, and management interviews are
all used to assess if information contained in the verified report is accurate.
Counter Verifiers follow the same practices that Verifiers do, including ensuring
the confidentiality of worker interviews.
5.2.5. Counter Verifications note and analyze any differences between facility responses,
corrected responses and what is observed on site during the Counter Verification.
5.2.6. For the purposes of Counter Verifications, “observed on site” means any
information obtained during a Counter Verification. This is not limited to visual
observations but can include information obtained through worker or
management interviews, document reviews, etc.

5.3. Differences between initial Verification results and Counter Verification results
5.3.1. Differences between facility responses and what is observed on site and
differences between corrected responses and what is observed on site will be
captured by Counter Verifiers.
5.3.2. Counter Verifiers will spend a portion of the Counter Verification determining the
underlying reasons for the differences between what is contained in the verified
report and what is observed on site. To do this analysis, Counter Verifiers may
conduct additional document review, worker interviews and/or management
interviews.
5.3.3. If a Counter Verifier observes any differences between what was reported during
the initial verification and the Counter Verification, they investigate fully to
determine whether the discrepancy is due to corruption or falsification of records.
5.3.4. Counter Verifiers will capture as much information as possible on the underlying
reasons for the discrepancies in the Counter Verification report.
5.4. Submission of Counter Verification Data to the VPM
5.4.1. If a Counter Verification is performed by a VB, the Counter Verifier submits an
initial Counter Verification Report to the VPM, using a standard report template
provided by the VPM.
5.4.2. The initial Counter Verification report includes data on what the Counter Verifier
assessed on-site, highlighting any differences between the initial verification and
the Counter Verification.
5.4.3. Initial Counter Verification reports are due to the VPM within 5 business days of
the Counter Verification.

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6. VPM Analysis of differences between initial Verification and Counter Verification
6.1. The VPM analyzes any differences between the initial Verification and the Counter
Verification. This assessment forms the basis for the VPM’s determination of whether
SAC processes were followed and if the verifier had the required skills and knowledge
to conduct the initial verification.
6.2. Based on information provided by the Counter Verifier, the VPM categorizes any
differences/discrepancies raised during the Counter Verification. The VPM assesses
whether the discrepancies were due to understandable point in time differences or due
to systemic oversight or other issues with the initial Verification.
6.3. The VPM may follow up with VB Counter Verifiers if additional clarifications are
necessary.

7. Final Counter Verification Report

7.1. Counter Verifications reports are completed using a standard report template.
7.2. Reports are completed within 15 business days of the Counter Verification.
7.3. Facilities receive a summary of the Counter Verification report that includes:
7.3.1. Details on the Counter Verification (when it took place, the party that conducted it,
etc.)
7.3.2. If there were no significant issues, confirmation that the Counter Verification did not
show any significant issues
7.3.3. If there were significant issues found during the Counter Verification that would
result in invalidation of the verification, a notification that the initial Verification is
invalidated
7.4. Verifier Bodies receive a summary of the Counter Verification Report that includes:
7.4.1. Details on the Counter Verification (when it took place, the party that conducted it,
etc.)
7.4.2. Summary of any issues identified during the Counter Verification that were missed
by the verifier (i.e. issues that were clearly present during the initial Verification and
not captured in the report)

8. Invalidating Reports
8.1. If the Counter Verification finds any of the issues listed in Appendix I, Extreme Cases, the
VPM may invalidate the report.
8.1.1. The VPM emails the facility and the VB informs that the report will be invalidated.
A short explanation of why the report is being invalided is provided.
8.1.2. Four calendar days after the facility and VB are informed, the VPM sets the report
status to VRI on Higg.org
8.2. Instances where reports are invalidated due to errors or oversights by the verifier will be
reflected in the verifier scorecard. If a Verification is invalidated due to bribery or to
significant issues with verifier performance, the VPM may suspend the verifier from
conducting additional verifications. Decisions to suspend verifiers will be made jointly by
the VPM and SAC.

Responsibilities

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Counter Verifiers: conduct Counter Verifications in line with this procedure and completing
Counter Verification reports.
VPM:
● Recruit and qualify Counter Verifiers to conduct Counter Verifications;
● Ensure that this procedure is followed consistently;
● Conduct QA reviews of Counter Verification reports;
● Determine Counter Verification facilities, in cooperation with SAC.
SAC: Approve updates and amendments to this procedure and determine Counter Verification
facilities, in cooperation with the VPM.
Brands and Facilities: Support and facilitate scheduling of Counter Verifications

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 E. Duplicate Verification (DV)
Duplicate Verifications are a repeat of a verification, done at a different point in time by a different
VB or the VPM. They are used to assess if Higg FEM Verification procedures are being followed,
whether verifiers have the skills and knowledge to conduct verifications, and whether verification
report content is generally accurate.

When inconsistencies in data are found between the original and duplicate verifications, the
VPM investigates further to assess whether it is a competency issue (e.g. individual verifier’s
knowledge and skills, training program), or a procedural issue (e.g. Verification Protocol quality,
VB management procedures), or an ethical issue (e.g. bribery, corruption)

Procedure

1. Duplicate Verifier Selection

1.1. Duplicate Verifications are performed by qualified Verifiers or the VPM.
1.2. VPM staff that perform the Duplicate Verifications meet the requirements for being a
qualified verifier.
1.3. VBs shall not perform Duplicate Verifications if they performed the initial Verification.
1.4. Duplicate Verifier shall not review the existing Higg vFEM, however, they will be
permitted to view the Higg FEM as they would a typical verification.
1.5. The VPM selects the VB based on factors including availability, experience and cost.
1.6. The VB selects the Duplicate Verifier from any approved Verifier available and provides
information on Verifier to the VPM for scheduling.

2. Duplicate Verification Facility Selection

2.1. All verified facilities are subject to Duplicate Verification.
2.2. Selection of facilities for Duplicate Verification is done jointly by the VPM and SAC.
2.3. Facilities will be chosen based on several criteria including risk factors, size, facility type
and geographic location.
2.4. The VPM contacts facilities to inform them of the Duplicate Verification.
2.5. Duplicate Verifications are announced. The VPM works with the facility and Duplicate
Verifier to find a suitable date for the Duplicate Verification.
2.6. There are no costs to facilities for Duplicate Verifications.

3. Duplicate Verification Preparation

3.1. Preparation is the same as for a standard verification.

4. Duplicate Verification Methodology

4.1. Duplicate Verifications consist of the same activities as a standard verification.

5. Submission of Duplicate Verification Data to the VPM

5.1. If a Duplicate Verification is performed by a VB, the Duplicate Verifier submits an initial
Duplicate Verification Report to the VPM, using a standard verification tool provided by
the VPM.
5.2. Initial Duplicate Verification reports are due to the VPM within 5 business days of the
Duplicate Verification

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6. VPM Analysis of differences between initial Verification and Duplicate Verification
6.1. The VPM analyzes any differences between the initial Verification and the Duplicate
Verification. This assessment forms the basis for the VPM’s determination of whether
SAC processes were followed and if the Verifier had the required skills and knowledge
to conduct the initial verification.
6.2. Based on information provided by the Duplicate Verifier, the VPM categories any
differences/discrepancies raised during the Duplicate Verification. The VPM assess if the
discrepancies were due to understandable point in time differences or due to systemic
oversight or other issues with the initial Verification.
6.3. The VPM may follow up with VB Duplicate Verifiers if additional clarifications are
necessary.

7. Final Duplicate Verification Report

7.1. Duplicate Verifications reports are completed using a standard report template.
7.2. Reports are completed within 15 business days of the Duplicate Verification.
7.3. Facilities receive a summary of the Duplicate Verification report that includes:
7.3.1. Details on the Duplicate Verification (when it took place, the party that conducted it,
etc.).
7.3.2. If there were no significant issues, confirmation that the Duplicate Verification did
not show any significant issues.
7.3.3. If there were significant issues found during the Duplicate Verification that would
result in invalidation of the verification, a notification that the initial Verification is
invalidated.
7.4. Verifier Bodies receive a summary of the Duplicate Verification Report that includes:
7.4.1. Details on the Duplicate Verification (when it took place, the party that conducted it,
etc.).
7.4.2.Summary of any issues identified during the Duplicate Verification that were missed
by the Verifier (i.e. issues that were clearly present during the initial Verification and
not captured in the report).

8. Invalidating Reports
8.1. If the Duplicate Verification finds any of the issues listed in Appendix I, Extreme Cases,
the VPM may invalidate the report.
8.1.1. The VPM emails the facility and the VB informs that the report will be invalidated. A
short explanation of why the Verification is being invalided is provided.
8.1.2. Four calendar days after the facility and VB are informed, the VPM sets the report
status to VRI on the Higg.org.
8.2. Instances where reports are invalidated due to errors or oversights by the verifier will be
reflected in the verifier scorecard. If a Verification is invalidated due to bribery or to
significant issues with Verifier performance, the VPM may suspend the Verifier from
conducting additional Verifications. Decisions to suspend Verifiers will be made jointly by
the VPM and SAC.

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Responsibilities
Duplicate Verifiers: Conduct Duplicate Verifications in line with this procedure and completing
Duplicate Verification reports.
VPM:
● ensure that this procedure is followed consistently;
● conduct QA reviews of Duplicate Verification reports;
● determine Duplicate Verification facilities, in cooperation with SAC.
SAC: Approve updates and amendments to this procedure and determine Duplicate Verification
facilities, in cooperation with the VPM.
Brands and Facilities: Support and facilitate scheduling of Duplicate Verifications

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 F. Shadow Verification (SV)
Shadow Verifications are an observation of a Verification to assess verifier performance. This
may be done by the VPM or self-nominated Brand or Manufacturer representatives (2nd
parties). During a Shadow Audit, the Shadow Verifier observes the verifier to confirm that SAC
protocols are followed and that the verification is conducted in line with SAC expectations.

Procedure

1. Shadow Verification Selection

1.1. Verifications are selected for shadowing by the VPM or brand/manufacturer
representatives.
1.2. Verifications are selected by the VPM randomly as well as based on risk.
1.3. Brand/Manufacturer shadows may be selected by the brand or manufacturer in
coordination with the VPM.
1.4. Shadow Verifications are announced to both the VB and the facility.
1.5. To facilitate Shadow Verifications, VBs must provide the VPM with information on
scheduling of Verifications when requested.

2. Shadow Verification Process

2.1. During the opening meeting the Shadow Verifier is introduced, and the purpose of the
Shadow Verification explained.
2.2. The Shadow Verifier observes the Verification process and notes instances where
Verification Protocols are not followed or where other SAC requirements are not met
by the verifier. The Shadow Verifier also notes any best practices.
2.3. Verifiers are assessed on how well they follow SAC protocols; their understanding of
the SAC system; professionalism; audit preparation; time management; reporting;
knowledge of local laws and regulations; knowledge of labor and human rights issues.
2.4. During the on-site verification, the Shadow Verifier does not actively participate in the
Verification. The Shadow Verifier does not gather information or provide guidance to
the Verifier. The Shadow Verifier may periodically ask the verifier questions for
clarification, but this should not interfere with the verification process.
2.5. The Shadow Verification includes a review of the finalized verification report to assess
how accurately the report reflects the on-site verification.
2.6. All observations are captured in the Shadow Verification report.

3. Shadow Verification Reporting

3.1. Shadow Verification outcomes are recorded using a standard report format.
3.2. Shadow Verification reports are completed within 15 business days of the verification
report being finalized.
3.3. VBs are provided with the Shadow Verification report.
3.4. Shadow Assessment outcomes are reflected in the verifier scorecard.

4. Invalidating Reports
4.1. If during the Shadow Verification, the VPM finds any of the issues listed in Appendix II,
Extreme Cases, the VPM may invalidate the report.
4.2. The VPM emails the facility and the VB informs that the report will be invalidated. A short
explanation of why the Verification is being invalided is provided.

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 4.3. Four calendar days after the facility and VB are informed, the VPM sets the report status
to VRI on Higg.org

Responsibilities
Shadow Verifiers: Conduct Shadow Verifications in line with this procedure
VPM:
● Ensure that this procedure is followed consistently;
● Conduct QA reviews of Shadow Verification reports;
● Determine Shadow Verification facilities, in cooperation with SAC.
SAC: Approve updates and amendments to this procedure and determine Shadow Verification
facilities, in cooperation with the VPM.
Brands and Facilities: Support and facilitate scheduling of Shadow Verifications

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 G. Feedback from Facilities
Feedback from SAC system users gives valuable information on the workings of SAC Verification
and the quality of verification actors, e.g. the VB and the Verifier. The VPM uses collected
feedback to populate verifier scorecards. Gathered information will contribute to ensuring quality
of Verification.

1. Feedback forms
1.1 A feedback form is sent to all facilities after they complete a verification. Facilities are
asked to provide comments on the verification process and verifier conduct.
Completing the form is optional.

2. Feedback outcomes
1.2.1 All feedback is captured and analyzed by the VPM. The VPM provides SAC with reporting
on feedback.
1.2.2 Feedback is used to determine if any SAC system users need additional training, guidance
or support.

3. SAC system users’ questions

2.1 Through howtohigg.org/request SAC system users can submit requests. Requests related
to Verification are automatically forwarded to the VPM.
2.2 Solved information requests are captured by the VPM for evaluation of the Verification
process.

Responsibilities
VPM: Collect feedback data into database; analyze feedback data;

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 H. Disputes
A dispute is an issue related to verifier conduct or the verifier not following the verification protocol.
The dispute process is not used to resolve issues or disagreements over verification outcomes of
specific questions. If the facility has concerns about specific verification answers and outcomes of the
verification, the Verifier should be made aware of those concerns at the closing meeting, so they can
be swiftly resolved within two days of the close of the on-site verification. The facility may also use
the period before the verification is finalized to resolve any question level issues directly with the
Verification Body (VB). This process does not require Verification Program Manager (VPM)
involvement and would not be considered as part of the dispute process.

1. Raising Disputes
1.1. Disputes are instances where a facility has an issue with their verified assessment. The VPM
receives such disputes.
1.2. Only facilities may raise disputes.
1.3. Disputes are raised on the Higg.org platform. When initiating a dispute, facilities are required
to provide information on the reason for the dispute. This information should be provided in
the Dispute survey which appears when the facility clicks “Dispute Verification” on the left
pane titled “Available Actions” in the module Overview section.
1.4. A facility has one opportunity per verification to raise a dispute. Multiple issues may be
included within a single dispute. For example, if the dispute is raised because the Verifier did
not spend enough time on site and because the Verifier did not speak the language of
management at the Facility, these issues are raised together in one dispute.
1.5. A facility should raise a dispute within 5 days of a verified module with the status being set
to VRC by Verifier

2. Substantiating Disputes
2.1. Within 5 working days, the VPM evaluates the dispute to determine if it is valid.
2.2. To be valid, a dispute must relate to Verifier conduct or the Verification Protocol and must
relate to a specific verification. Question level issues are not considered valid disputes.
2.3. If a dispute is not substantiated, the VPM sets the status of the verified module to VRF on
Higg.org.
2.3.1. The VPM notifies the Facility that the dispute is not substantiated.
2.3.2. Within 5 working days after the notification, the VPM sets the status to VRF.
2.4. Disputes that are not substantiated may be treated as complaints. This does not impact the
status of the verified assessment.

3. Investigating Disputes
3.1. If a dispute is substantiated, the VPM investigates.
3.2. The Facility, Verifier and/or VB may be contacted to provide additional information.
3.3. The VPM may consult with SAC regarding the dispute.
3.4. The VPM shall resolve all disputes within 10 working days, unless there is coordination issue
with the related parties.

4. Outcomes of Disputes
4.1. There are three potential outcomes of a dispute: 1) the VPM determines a change is needed
to the report, 2) the VPM determines the report is invalidated or 3) the VPM determines no
change is required and the report is finalized with no edits.
4.1.1. If the VPM determines that a change is needed to the report:
4.1.1.1. The VPM informs the Verifier and Facility of the change required.
4.1.1.2. The VPM sets the status of the verified module to VRC.
4.1.1.3. The Verifier and the Facility have 7 days to make and review the change.

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 4.1.1.4. On the 8th day, the status of the verified module automatically changes to VRF
unless the facility selected the VRF prior to day 7.
4.1.2. If the VPM determines there were significant issues and the verification meets the
criteria for invalidation (see Appendix II in the QA Manual for criteria for invalidating a
verification):
4.1.2.1. The VPM informs the verifier and the facility that the verification will be invalidated.
4.1.2.2. Within 5 days after the VPM informs the verifier and the facility, the VPM sets the
status to VRI.
4.1.3. If the VPM determines that there are no changes needed to the report:
4.1.3.1. The VPM informs the verifier and the facility that the verification report will not be
changed.
4.1.3.2. Within 5 days after the VPM informs the verifier and the facility, the VPM sets the
status to VRF.

5. Tracking and Reporting on Disputes

5.1. All disputes received by the VPM are tracked.
5.2. Outcomes of the dispute are reflected in the verification report in one of the following ways:
• Dispute not substantiated: status set by VPM to VRF
• Dispute substantiated: status set by VPM to VRC
• Dispute substantiated: status set by VPM to VRI

Responsibilities
VPM: Collect, review and investigate disputes.

Examples of incidents which can be substantiated as Dispute

• Verifier failed to spend the appropriate amount of time to properly assess the accuracy
of the facilities self-assessment data. E.g. Although it was recommended that the
Verifier spend two days as per person-day guidance, the verifier only spent one day
and also failed to review all of the energy use documentation provided by the facility.
This lack of review of documentation resulted in the Verifier wrongly noting the self-
assessment question as ‘inaccurate.’ This would be a failure to follow the established
protocols and would be considered unprofessional behavior.

Examples of incidents which can NOT be substantiated as Dispute

The facility provided an environmental strategy document to the verifier. Upon review the
Verifier determined in their judgement the document did not meet the minimum requirement
for a “Yes” and marked the facilities answer of “Yes” as ‘inaccurate’ and corrected the response
to “No.” The facility disagrees with this assessment. This would be question level disagreement
on the verifier’s judgement. These should be addressed directly with the verifier and Verifier
Body on a collaborative way during the VRC status.

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 I. Verifier Scoring
Verifier Scoring takes data from the QA process and uses it to rate verifier performance.

Procedure

1. Scoring Inputs
1.1. The following sources of data on Verifier performance are used to calculate the verifier
Score:
● Verifier exam scores
● Desktop Review outcomes
● Counter Verification outcomes
● Duplicate Verification outcomes
● Shadow Verification outcomes
● Facility feedback

2. Scoring Criteria
2.1. Verifier performance is rated by the VPM according to set criteria.
2.2. A score is provided for each verification for which data is available.
2.3. The scoring inputs described in 1.1 are aggregated into a single numeric verifier score.
2.4. The verifier score is an average score from all verifications for which scores exist.
2.5. Inputs are weighted based on importance (QA items are considered more important than
feedback).
2.6. Data on scores is stored in VPM database and attached to each verification.

Responsibilities
VPM: Collect scoring data and calculate verifier scores

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Appendices

Appendix I – Extreme Cases (for Invalidating Reports)

When a verified assessment report is considered invalid, the status ‘’invalidated’’ is attributed in
the Higg.org and all stakeholders are notified (facility, verifier, end user).

Verified assessment report is considered invalid when:

1. Basic quality standards are not met:

a. Tool not completed (over 5 percent of the questions left blank)
b. Tool not completed in English
c. Significant number of findings not supported with evidence
d. Significant number of findings not clearly communicated (findings are not written clearly;
findings can be interpreted in more than one way; questions not correctly answered)

2. Verifier requirements are not met:

a. Verifier not approved by VPM
b. Verifier visiting facility for second time in a row without registering this in the Repeat
Verification Registry
https://www.sumerra.com/programs/sac/sac-fem-verification-program/fem-repeat-request/
c. Verifier provided facility with consulting services within 12 months of verification
d. Verifier did not spend sufficient man-days on site

3. Significant issues with the Verification process are found:

a. Evidence of bribery (solicited or accepted by verifier)
b. Evidence of prohibited ‘selling’ of products or services in violation of the terms
c. Verifier was denied access to facility grounds (entirely or in part)
d. Verifier was denied access to workers (interviews)
e. Verifier was denied access to information (documents)
f. Findings at the verified site were not captured in the report

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Appendix II – List of Abbreviations

FEM Higg Facilities Environmental Module

QA Quality Assurance
SAC Sustainable Apparel Coalition
VB Verifier Bodies
VPM Verification Program Manager
VRI Verification Invalidated

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