Your Supply Chain Health Check: Identifying the top 8 common non-compliances with SMETA

In today’s globalized marketplace, ethical and responsible business practices are no longer a niche concern but a core expectation. For companies operating within complex supply chains, ensuring compliance with social and ethical standards is paramount. The Sedex Members Ethical Trade Audit (SMETA) has emerged as one of the world’s most widely used social audit methodologies, providing a framework for assessing working conditions, health and safety, environmental performance, and business ethics.

A SMETA audit is not merely a pass/fail exercise. It is a collaborative process designed to identify areas for improvement and drive positive change. When non-compliances are identified, a Corrective Action Plan Report (CAPR) is created, outlining the steps required to address the issues within a specified timeframe.

From Regulation to Practice:
How SMETA Supports Supply Chain Due Diligence

Across multiple jurisdictions, companies are now subject to mandatory human rights and environmental due diligence requirements. These regulations require organisations to demonstrate that effective, risk-based systems are in place to identify, prevent, mitigate, and address adverse impacts within their supply chains. In this context, SMETA (Sedex Members Ethical Trade Audit) is commonly used as a voluntary due diligence tool to support supplier risk identification and monitoring.

  • EU Corporate Sustainability Due Diligence Directive (CSDDD) – Requires large companies to identify and address human rights and environmental impacts across their value chains
  • UK Modern Slavery Act 2015 – Requires transparency on actions taken to prevent forced labour and human trafficking
  • German Supply Chain Due Diligence Act (LkSG) – Requires structured human rights and environmental risk management systems
  • France’s Duty of Vigilance Law – Requires companies to implement vigilance plans covering human rights and environmental risks
  • California Garment Worker Protection Act (SB-62) – Strengthens accountability for labour practices and enforcement of supplier codes of conduct

SMETA—particularly 2-pillar audits (Labour Standards and Health & Safety) and 4-pillar audits (including Environment and Business Ethics) can support both social and environmental due diligence, when findings are integrated into governance, remediation, and monitoring processes.

Common SMETA Non-Compliances

Based on audit data and industry reports, a number of recurring non-compliances are frequently identified during SMETA audits. Understanding these common pitfalls is the first step toward proactive compliance.

Non-Compliance Category

Common Issues

Working Hours & Rest Days

Excessive overtime, failure to provide mandated rest days, exceeding legal weekly hour limits (48 hrs/week standard, 60 hrs/week maximum).

Wages & Benefits

Incorrect calculation of overtime pay, unauthorized deductions, failure to pay minimum wage.

Time Records

Incomplete, inaccurate, or falsified time records.

Health & Safety

Missing risk assessments, inadequate PPE, insufficient training. Chemical safety issues are the second most common non-compliance type.

Fire Safety

Blocked exits, faulty alarms, inadequate drills, expired extinguishers.

Chemical Management

Improper storage, missing or outdated Safety Data Sheets (SDS), lack of worker training.

Grievance & Disciplinary Procedures

Weak documentation, lack of formal processes, fear of retaliation.

Contractor & Subcontractor Control

Failure to ensure contractors meet ethical standards.

Proactive Compliance: Best Practices for Success

Organizations can take several proactive steps to embed ethical practices into their operations:

  • Conduct a thorough self-assessment before the official audit to identify and address potential issues
  • Develop a robust management system with clear policies and documentation for all SMETA areas
  • Engage and train your team so all employees understand SMETA requirements and their roles
  • Address previous audit findings to demonstrate continuous improvement
  • Foster a culture of continuous improvement by viewing audits as opportunities, not just compliance exercises

Conclusion

SMETA compliance is an ongoing journey, not a destination. By proactively addressing common non-compliances, organizations can build resilient, ethical, and sustainable supply chains, ensuring long-term business success while benefiting workers and the environment. 

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