I arrive at the factory gate at 7:30 AM. The guard already knows I’m coming — the audit was announced three weeks ago. [PLACEHOLDER: describe specific gate detail, type of factory, province]. What I notice first isn’t the building. It’s the workers queuing at the entrance.
How a queue moves tells you a great deal about how a facility manages time pressure, whether supervisors are present, and whether workers feel comfortable at their own workplace. I’ve been doing this for nineteen years, and the first ten minutes before I’ve said a word to management still tell me more than the first two hours of document review.
The Opening Meeting
Management is usually prepared. A folder on the table. Certificates in plastic sleeves. A presentation with an ESG slide deck someone printed yesterday. [PLACEHOLDER: specific detail about what factories typically prepare].
What I do differently than most auditors: I don’t start with the folder.
I start by asking the general manager to walk me through the last six months — in their own words, not from documentation. What was hard? What changed? What are they not proud of?
Most managers are surprised by the question. Some relax. A few become guarded in a way that tells me exactly where to look first.
The prepared folder comes later. What I hear in those first fifteen minutes — the hesitations, the things mentioned quickly and moved past — is usually more informative than everything in the plastic sleeves.
The Facility Walk
I do my own walk. Not the tour management wants to give me — the route I choose, at my own pace, doubling back when something catches my eye.
Here is what I’m looking for, and why each of these matters more than most people think:
Emergency exits and egress. Not whether they exist, but whether workers could actually reach them under realistic conditions — with machinery running, aisles at production-floor density, during a shift change. [PLACEHOLDER: insert a specific observation from a real audit, anonymised].
Notice boards. The compliance version of a notice board is laminated and untouched. The real version has recent additions, some handwriting, evidence that workers have read and interacted with what’s posted. A perfectly preserved notice board is a finding.
The break area. Who uses it, how it’s equipped, whether it’s accessible during shifts. In facilities where workers eat at their machines, there is usually a documented break room that exists for audit purposes only.
Personal protective equipment storage and condition. Not whether PPE is available but whether it fits, whether it’s being used, and whether workers know why they’re using it or just that they must when an auditor is present. [PLACEHOLDER: a specific example of PPE theatre vs. genuine use].
The dormitory, if present. [PLACEHOLDER: this section requires Lukas’s specific experience — dormitory audits have distinct protocols].
I take photographs throughout. Not of workers’ faces — that’s never appropriate without consent — but of physical conditions, equipment states, signage, and anything I’ll need to reference in my report. Management sometimes asks me to stop photographing. I explain what I can and cannot photograph under the audit protocol. I don’t stop.
Worker Interviews
This is the part of an audit that matters most and is most frequently done poorly.
I conduct interviews separately from management. Always. Without exception. This is a non-negotiable condition of every engagement I accept. If a factory insists that a supervisor or HR officer must be present during worker interviews, I end the interview immediately and note the obstruction in my report.
[PLACEHOLDER: insert the story about the training session cancellation — the one where supervisors were watching from the back — as an illustration of the same principle applied to training].
The five questions I always ask, in some version:
“Can you tell me what you do here — what a normal day looks like?” Not a compliance question. A calibration question. I’m learning their vocabulary, their level of comfort speaking with me, and whether they’ll describe conditions in present tense or learned audit-script past tense.
“If something felt wrong — unfair, unsafe, or uncomfortable — what would you do?” This is the grievance mechanism question, asked without using the words “grievance mechanism.” Workers who answer “I would go to HR” have either experienced a functioning system or been drilled on the correct answer. The follow-up — “Has that happened? What was the result?” — distinguishes the two.
“What’s the hardest part of the job?” Open-ended, humanising. Workers who have been coached for audits often give safety answers here. Workers who haven’t been coached tell you what it’s actually like to work in this facility.
“Do you know what your wages include — the deductions, the overtime calculation?” Most workers do not. Not because they’re uninformed, but because the payslip is designed not to be legible. When a worker can walk me through their own payslip, that facility is doing something right. [PLACEHOLDER: specific payslip complexity you’ve encountered].
“Is there anything you’d like me to know that I haven’t asked?” I ask this last, after trust has been built. The answers here are the ones that end up in findings. [PLACEHOLDER: an anonymised example of something discovered through this question].
I conduct between twelve and twenty interviews for a medium-sized facility. Not all of them are formal, structured conversations — some happen during the facility walk, in passing, in ways that feel more like conversation than interrogation. Workers who have been coached to give safe answers in a formal interview will often drop the script in an informal one.
Document Review
By the time I reach documents, I already have a picture. The documents either confirm what I’ve seen or create new questions.
The gap between what records say and what the floor shows is the defining feature of most compliance failures I find. [PLACEHOLDER: a specific example where payroll records vs. worker-reported wages diverged].
Overtime records are the most consistently unreliable. Not because they’re falsified — though that happens — but because overtime calculation in Vietnamese manufacturing [PLACEHOLDER: Vietnamese law specifics — reference Labor Code Article X] is genuinely complex, and most facilities have never had anyone sit down and verify their own calculation methodology is correct.
I look for:
- Consistency across documents — do the attendance records, payroll records, and overtime approvals tell the same story?
- Gaps in records — a missing month in health and safety inspection logs is not usually an oversight.
- Signatures — who signed what, and whether those people are still employed in the role the signature implies they held.
- The date problem — documents with suspiciously close creation dates across a broad period. [PLACEHOLDER: this is a sensitive one — Lukas should decide how explicitly to describe this].
The Closing Meeting
I deliver findings at the end of the day. Always the same day — findings left overnight become findings that management has revised their response to before I’ve finished writing them.
Here is what I refuse to do in a closing meeting:
I will not soften a critical finding because the management team is upset. I have been told the finding will damage a relationship with a buyer. I have been offered revisions to my report. I have had closing meetings where the general manager cried. The finding remains.
I will not present findings as questions. “We noticed that perhaps the overtime records may possibly have some discrepancies” is not how I communicate. A finding is a finding. I describe it, I reference the standard clause it falls under, and I describe what corrective action looks like. The facility may disagree. They can note that disagreement in their corrective action response. But the finding is what I observed.
What I do try to do: separate the finding from the person. A facility that has a grievance mechanism problem doesn’t have a corrupt management team — usually, it has a management team that has never been shown what a functioning grievance mechanism looks like in practice. The closing meeting is partly about findings and partly about what a better version of this facility could look like.
[PLACEHOLDER: insert specific language Lukas uses in closing meetings — the phrasing that defuses defensiveness without softening the message].
The Drive Home
I think about the workers I spoke to. [PLACEHOLDER: a specific, anonymised worker interaction that stuck — Lukas should choose this].
The work is repetitive in structure and completely different in practice every time. Every facility has a different set of pressures — buyer deadlines, seasonal production cycles, market conditions that have nothing to do with compliance but shape everything about how compliance is managed.
What doesn’t change: the workers are real people, their working conditions are the actual subject of every standard I audit against, and whether an audit makes a difference depends entirely on whether the person conducting it believes that.
I believe that. Nineteen years in. Still.
Trần Xuân Quang is a senior social compliance advisor and independent auditor based in Vietnam. He holds SA8000, RBA, and CQI/IRCA ISO 9001 Lead Auditor credentials and has conducted over [PLACEHOLDER: number] audits across Southeast Asia.
