ESCP Certification: What the New Ethical Supply Chain Audit Checklist Covers

ESCP certification is issued by the Ethical Supply Chain Program (ESCP), formerly known as the ICTI Ethical Toy Program, and it's earned by passing a factory audit against the ESCP Audit Checklist, currently Version 4.0, effective from 1 July 2024. The checklist covers 13 sections spanning business ethics, employment practices, working hours, compensation, and health and safety, each scored against a tiered compliance system rather than a simple pass or fail. This article breaks down what the checklist actually asks for, how the audit and certification process works, and what to check first if you're preparing for one.

What is ESCP certification?

ESCP is a social compliance program originally built for the toy industry and now applied across multiple manufacturing sectors. Certification is issued at the factory level once an accredited third-party audit firm, such as SGS or TÜV Rheinland, completes an on-site audit and the ESCP Monitoring and Development Team reviews the results and confirms the facility meets the checklist requirements. A factory that passes receives the ESCP Seal of Compliance.

What the ESCP Audit Checklist actually covers

The current checklist, Version 4.0, is organised into 13 sections:

  1. Audit Process, covering transparency and prevention of auditor interference;

  2. Business Ethics, covering integrity policies, training and how the factory manages its own business partners;

  3. Employment Practices, covering recruitment, contracts, underage workers and foreign migrant workers;

  4. Special Protections for young workers and pregnant or breastfeeding workers;

  5. Working Hours, including policies, documentation, maximum hours and breaks;

  6. Compensation, covering wages, benefits, withholdings and pay slips;

  7. Disciplinary Practices, covering policies that prohibit abuse;

  8. Forced and Prison Labor, covering voluntary employment and freedom of movement;

  9. Discrimination, covering protections from hiring through termination;

  10. Grievance Mechanisms, covering worker representation and communication channels;

  11. Facilities, covering security, building safety, housekeeping, sanitation, medical provisions and vehicles;

  12. Fire and Emergency, covering preparedness, exits, fire systems, drills and electrical safety;

  13. EHS, covering environmental health and safety programmes and training.

How findings are scored

Rather than a single pass or fail result, each checklist item is rated on a tiered scale: Zero Tolerance, Critical, Major, Minor, or Not Applicable. Zero Tolerance items, such as evidence of forced labour, are treated as immediate, non-negotiable failures. Other items scale by severity, and the checklist sets specific numeric thresholds for some of them rather than leaving the rating to interpretation. For example, working hours above 78 hours a week are rated Critical, while 72 to 78 hours a week is rated Major. Documentation gaps follow a similar pattern: 20 percent or fewer of sampled records being incomplete or containing errors is rated Major, while more than 20 percent is rated Critical.

Other checkpoints are stated as flat requirements rather than a sliding scale. Workers need 100 percent injury insurance coverage, wages need to be paid directly to workers, and fire drills need to be conducted at least twice a year, or quarterly for facilities without fire hydrants or sprinklers.

How the certification process works

Factories register and manage their certification through ESCP's Connect platform, which is also the program's responsible sourcing hub for brands and retailers. Registration requires two separate fees: a registration fee paid to ESCP and an audit fee paid directly to the assigned audit firm. Once registered, an accredited third-party audit firm is assigned and the audit itself is arranged and completed within two months.

After the audit, ESCP's Monitoring and Development Team reviews the auditor's findings along with the factory's corrective action plan for any non-compliances raised, and issues a certificate once the requirements are met. A final seal fee is paid before the factory receives its Seal of Compliance. Factories can track their certification status, audit reports and corrective action plans through the Connect platform on an ongoing basis. ESCP's own published pages don't specify one universal validity period for a certificate across all facilities, so it's worth confirming your specific renewal date directly with your assigned audit firm or through the Connect platform rather than assuming a fixed interval.

Where to focus preparation first

Working hours and compensation records are worth reviewing early, since the checklist ties both to specific numeric thresholds rather than general policy language, which means an auditor is checking actual time and payroll records against the 78-hour and 72-hour markers rather than taking a written policy at face value. Health and safety documentation, particularly injury insurance coverage and fire drill records, is another area where the checklist is specific enough that gaps are easy for an auditor to identify quickly.

Not sure where your factory stands against the checklist?

Working through 13 sections of scored checkpoints before committing to an audit date is easier with a second set of eyes on the documentation. If that would help, get in touch and we can talk through where your factory's systems are likely to hold up and where they need work first.

Frequently asked questions

What is the ESCP Audit Checklist?

It's the standard ESCP-accredited auditors use to assess a factory, currently Version 4.0, effective from 1 July 2024. It's organised into 13 sections covering business ethics, employment practices, working hours, compensation, health and safety, and related areas.

How is an ESCP audit scored?

Each checklist item is rated Zero Tolerance, Critical, Major, Minor, or Not Applicable, rather than a simple pass or fail. Some items have specific numeric thresholds, such as weekly working hours, that determine which rating applies.

What happens after a factory passes its ESCP audit?

ESCP's Monitoring and Development Team reviews the audit findings and any corrective action plans, issues a certificate once requirements are met, and the factory receives the ESCP Seal of Compliance after a final seal fee is paid.

How long does an ESCP audit take to arrange?

Once an accredited third-party audit firm is assigned through the Connect platform, the audit is arranged and completed within two months.