Coca Cola Guideline

The Coca-Cola Company
Worldwide Licensing Department
Code of Conduct for Licensees/Suppliers and their Manufacturers of Merchandise bearing any trademarks of TCCC or its subsidiaries (Collectively referred to as
¡��Merchandise Manufacturers¡��)
Table of Contents
• Introduction
• WWL Code of Conduct for Merchandise Manu
• Compliance with Applicable Laws and Standard
• Principles of Citizenship
• Restrictions
• Executive Office Memorandum (Attachment A)
• Labor Watch Area (Attachment B)
• Third Party Auditing Procedure
• Approved Third Party Auditors (Attachment C)
• Audit Execution
• Corrective Action Plan
• Audit Follow-up
• Audit Letter to Manufacturers (Attachment D)
• Audit Framework
Introduction
The reputation of The Coca-Cola Company (¡��TCCC¡��) is built on trust. Those who do business with us around the world know we are committed to managing our business with a consistent set of values that represent the highest standards of quality, integrity, excellence, compliance with law and respect for the unique customs and cultures in communities where we operate. We seek to develop relationships with Licensees/Suppliers and/or their manufacturers of merchandise bearing trademarks of TCCC or its subsidiaries (collectively referred to ¡��Merchandise Manufacturers¡��) that share similar values and conduct business in an ethical manner.
As part of our ongoing effort to develop and strengthen our relationships with Merchandise Manufacturers that use trademarks of TCCC, our Worldwide Licensing Department (¡��WWL¡��) is introducing TCCC¡®s Code of Conduct for Merchandise Manufacturers (¡��Code¡��). The Code is based upon our belief that good corporate citizenship is essential to our long-term business success and must be reflected in our relationships and actions in the marketplace, the workplace, the environment and the community.
Recognizing there are differences in laws, customs and economic conditions that affect business practices in various parts of the world, we believe that shared values must serve as the foundation for relationships between TCCC and our Merchandise Manufacturers. The Code restates our requirements and emphasizes good workplace policies that comply with applicable environmental and local labor laws.
We look forward to working with you to ensure understanding of and compliance with requirements set forth in this program for you and all Merchandise Manufacturers for TCCC.
TCCC¡¯s Code of Conduct for Merchandise Manufacturers
Workplace Practice
At TCCC, we support fair employment practices in our relationship with our employees consistent with a commitment to human rights in our workplace, and we seek to provide a safe environment in which to work. We abide by all applicable labor laws addressing working hours, compensation, employees¡¯ rights to choose whether to be represented by third parties and to bargain collectively, working conditions, and other such workplace practices. We seek to create a workplace where individuals are treated with dignity, fairness and respect. We recognize value, respect and celebrate the cultural differences and diversity of background and thought of our employees.
We expect our Merchandise Manufacturers to follow applicable laws, and similar standards and principles in the countries in which they operate. TCCC¡¯s Code defines requirements concerning working conditions that must be met by the Merchandise Manufacturers in the production of merchandise bearing any of our trademarks.
Work Environment
We expect our Merchandise Manufacturers to judge their employees and contractors based upon their ability to do their jobs and not upon their physical and /or personal characteristics or beliefs, affirming the principle of no unlawful discrimination based on race, color, gender, religion, national origin or sexual orientation.
Health and Safety
All Merchandise Manufacturers must provide a safe and healthy working environment to minimize the risk of accidents, injury, and exposure to health risks. Merchandise Manufacturers must ensure that workers have access to portable clean drinking water, clean sanitary facilities, adequate lighting and ventilation in the working area and an adequate number of fire extinguishers and fire exists.Merchandise Manufactures must also ensure the same standards apply to worker housing facilities and canteens. The manufacturer shall implement training designed to reduce injuries and promote safe working conditions.
Child Labor
We expect our Merchandise Manufacturers to not employ anyone under the legal working age as defined by local law. The term ¡��child¡�� refers to any person aged 15 years or younger, or if a country¡¯s local law mandates a higher minimum working age than 15 years, a child of that purposes of that country means any person who is younger than the higher legal minimum working age. If the local law mandates a higher working age than 15, then the higher age would apply. Official documentation for every worker¡¯s date of birth must be maintained.
Forced Labor
We expect our Merchandise Manufacturers to not use forced or involuntary labor in which a worker does not voluntarily offer himself or herself. This includes all manner of involuntary work such as bonded, prison and indentured.
Wages and benefits
We expect our Merchandise Manufacturers to compensate their employees fairly and competitively relative to their industry in full compliance with applicable local and national wage and hour laws and to offer opportunities for employees to develop their skills and capabilities.   This includes applicable laws regarding minimum wage, overtime, hourly or by piece rate. The Merchandise Manufacturer shall provide legally mandated benefits as stated in the local or national law.
Working hours
The Merchandise Manufacturers shall not require workers to work more than 48 hours per week and 12 hours overtime or 60 hours per week. The requirement also includes any established working hours regulations set forth by local or national law. In addition, manufacturer must guarantee that workers will receive at least one day off in every seven-day period.
Collective Bargaining
In the event employees have lawfully chosen to be represented by third parties, we expect our Merchandise Manufacturers to bargain in good faith and not to retaliate against employees for their lawful participation in labor organization.
Environmental practices
We expect our Merchandise Manufactures to conduct business in ways that protect and preserve the environment. At a minimum, we expect our suppliers to meet applicable environmental laws, rules and regulations in their operations in the countries in which they do business.   Apply to all Merchandise Manufacturers including all subcontractors/sub-manufacturers utilizing our trademarks. TCCC¡¯s Code applies to all subcontractors/ sub-manufacturers at all tiers of the relationship (e.g. sub of sub or sub of sub) utilizing our trademarks. These subcontractors/ sub-manufacturers at all tiers are collectively deemed to be Merchandise Manufacturers.
Monitoring Compliance and Authorization
Merchandise Manufacturers shall designate one or more of its management to monitor factory compliance with standards set forth herein. Merchandise Manufactures shall use one of TCCC approved firms that specializes in social compliance. Each Merchandise Manufacturer must conduct such compliance monitoring on an annual basis and must submit such verification of compliance to TCCC. Merchandise Manufacturers will authorize TCCC designated agents to engage in factory audits to confirm compliance. These visits will include unannounced on-site inspections of manufacturing facilities; a review of all employee related books; and private interviews with employees. Any Merchandise Manufacturer who does not comply with TCCC¡¯s Code standards or refuses to allow inspection is subject to immediate termination by TCCC. In order to be authorized to use our trademarks each Merchandise Manufacturer must provide TCCC with a copy of a passing social compliance inspection within one year of the date of initial authorization. This must be provided annually from the date of the passing inspection used for the authorization. TCCC must have the right to verify the copy with the inspecting company.
Exception
When purchasing through Li & Fung (Trading) Limited (¡��Li & Fung¡��), TCCC¡¯s promotional merchandise, sourcing and service provider, social compliance inspections of Merchandise Manufacturers are conducted by Li & Fung¡¯s internal social compliance inspection team. Pursuant to our agreement with Li & Fung, this team has been approved by WWL to monitor social compliance and engage in factory audits to confirm compliance by each Merchandise Manufacturer that utilizes our trademarks. Li & Fung¡¯s social compliance team provides TCCC with annual ¡®passing¡¯ inspection reports for each Merchandise Manufacturer. In addition, WWL closely monitors Li & Fung¡¯s internal social compliance inspection team¡¯s performance.
Communications
We expect our Merchandise Manufacturers to communicate these Code principles for Merchandise Manufacturers to their employees. These principles should be provided in the local language and posted in an accessible place. We also expect our Merchandise Manufacturers to develop and implement appropriate business mechanisms to monitor compliance with these principles.
Compliance with Applicable Laws and Standards
At a minimum, Merchandise Manufacturers will be required to meet the following standards with respect to their operations as a whole:
•        Laws and Regulations
Merchandise Manufacturers will comply with all applicable laws, rules, regulations and requirements in the manufacture and distribution of our products and supplies and in providing services to TCCC.
•        Child Labor
Merchandise Manufacturers will not use child labor as defined by local law.
•        Forced Labor
Merchandise Manufacturers will not use forced or compulsory labor
•        Abuse of Labor
Merchandise Manufacturers will not physically abuse employees
•        Collective Bargaining
Merchandise Manufacturers will respect employees¡¯ rights to choose whether to be represented by third parties and to bargain collectively in accordance with local law.
•        Wages and Benefits
Merchandise Manufacturer¡¯s wages and benefits will comply with local law
•      Working Hours
Merchandise Manufacturer¡¯s working hours and overtime will comply with local law.
•        Health and Safety
Merchandise Manufacturer¡¯s working conditions will comply with local regulations.
•        Environment
Merchandise Manufacturers will comply with all applicable environment laws.
Principle of Citizenship
Our reputation is built on trust. Through good citizenship we will nurture our relationships and continue to build that trust. That is the essence of TCCC promise - to benefit and refresh everyone who is touched by our business. Wherever TCCC does business, we strive to be trusted partners and good citizens. We are committed in managing our business around the world with a consistent set of values that represent the highest standards of integrity and excellence. We share these values with our Merchandise Manufacturers making their system strong.
Marketplace
We will adhere to the highest ethical standards, knowing that the quality of our products, the integrity of our brands and the dedication of our people build trust and strengthen relationships. We will serve the people who enjoy our brands through innovation, superb customer service, and respect for unique customs and cultures in the communities where we do business.
Workplace
We will treat each other with dignity, fairness and respect. We will foster an inclusive environment that encourages all employees to develop and perform to their fullest potential, consistent with a commitment to human rights in our workplace. TCCC¡¯s workplace will be a place where everyone¡¯s ideas and contributions are valued and where responsibility and accountability are encouraged and rewarded.
Environment
We will conduct our business in ways that protect and preserve the environment. We will integrate principles of environmental stewardship and sustainable development into our business decisions and processes.
Community
We will contribute our time, expertise and resources to help develop sustainable communities in partnership with local leaders. We will seek to improve the quality of life through locally relevant initiatives wherever we do business.
Responsible corporate citizenship is at the heart of TCCC¡¯s promise. We believe that what is best for our employees, for the community and for the environment is also best for our business.
Restrictions
Stitched Soccer Balls (Footballs) Restrictions
All stitched soccer balls featuring TCCC¡¯s trademarks must be sourced solely through Merchandise Manufacturers authorized and managed by WWL, as set forth in the TCCC Executive Office Memorandum dated 30 January, 2003 (see Attachment A).
WWL is responsible for all stitched soccer ball agreements, warranties, ongoing inspection of manufacturing facilities and stitching centers, and the testing of all stitched soccer balls. WWL will make certain that the authorized Merchandise Manufacturers meet TCCC¡¯s social compliance requirements. Additionally, all stitched soccer ball manufacturing must take place in authorized facilities/stitching centers and all inventory must be tightly controlled from production all the way through shipping. Given the extreme high risk associated with stitched soccer balls, extra controls are required.
Geographic Restrictions
TCCC has compiled a list of countries and geographic regions where unfair working conditions may have been reported or suspected. Please review the Watch Area outlined in Attachment B. In addition, Cambodia is reported to have a very high rate of social compliance issues; therefore, use of Merchandise Manufacturers in Cambodia for the supply of merchandise bearing TCCC¡¯s trademarks outside of Cambodia is not authorized.
Countries under U.S. Trade Embargo
TCCC will not allow production in any country under trade embargo by the U.S. This list includes countries such as Angola, Afghanistan, Burma, Cuba, Iran, Iraq, Libya, North Korea and Syria. This list is not exhaustive and is accurate as of the date of this publication. Countries under current embargo are listed on ¡��Office of Foreign Assets Control¡�� website at ¡��www.treas.gov/offices/eotffc/ofac/sanctions/index.html¡�� under the link entitled ¡��Sanctions Program and Country Summaries¡��. Please refer to this site and follow the restrictions which apply as a matter of law.
Antiboycott Issues
The antiboycott laws require U.S. firms to refuse to participate in foreign boycotts that the U.S. does not sanction. They have the effect of preventing U.S. firms from being used to implement foreign policies of other nations which run counter to U.S. policy. The Arab League boycott of Israel is the principal foreign economic boycott with which U.S. companies must be concerned.
The following are some of the types of conduct that we must avoid in order to comply with the U.S. laws: agreement not to do business with Israel or a company blacklisted for doing business with Israel (the simple agreement, even if not carried out is illegal), agreement to discriminate against other persons based on race, religion, sex, national origin or nationality, and implementation of letters of credit or any other form of contract containing prohibited boycott terms or conditions. Even if we do not agree to participate in any of the above, the fact that someone requests that we do so triggers our obligation under law to report the incident to the US government.
Useful Internet sites:
www.treas.gov/ofac OFAC sanctions and specially designated nationals information.
www.bxa.doc.gov US Department of Commerce Bureau of Export Administration.
www.state.gov US Department of State country reports.
www.stat-usa.gov   This US DOC site provides a lot of practical import/export info for countries around the world.
ATTACHMENT A
EXECUTIVE OFFICE MEMORANDUM
TO: OFFICERS AND DEPARTMENT HEADS, THE COCA-COLA COMPANY, HEADS OF OPERATING DIVISIONS AND SUBSIDIARIES
ATLANTA, GEORGIA, January 30, 2003
EOM# 03-06
Effective immediately, all stitched soccer balls featuring our company's trademarks must be sourced solely through suppliers/manufacturers authorized and managed by the Worldwide Licensing Department of The Coca-Cola Company.
In the past, press reports linked the Coca-Cola trademark to stitched soccer balls allegedly produced for various World Cup sponsors under unacceptable working conditions. Even though we believe the balls in question were counterfeit, we recognize the serious nature of these allegations and are taking additional steps to ensure that the Coca-Cola trademark and reputation are protected.
Specifically, Worldwide Licensing is responsible for supplier agreements, warranties, ongoing inspection, and the testing of all stitched soccer balls. It will make certain that our authorized suppliers meet the company's social compliance requirements. In addition, this group will be responsible for leveraging the Coca-Cola system's purchasing power to source policy-compliant soccer balls at competitive prices.
Regarding unacceptable working conditions, it is the policy of The Coca-Cola Company not to use child labor, pay unreasonably low wages and/or maintain unsafe working conditions in connection with any promotional merchandise bearing our trademarks. Given the extreme high risk associated with stitched soccer balls, extra controls are required. The company will continue to assess the risk and control of other items on an ongoing basis and may expand Worldwide Licensing's accountability beyond stitched soccer balls, as necessary.
Accountability for compliance with the company's promotional merchandise policies remains with the Division Presidents. To further understand the company's policies relative to promotional merchandise, please refer to EOM #02-09.
Please share this information with your teams and Bottlers, and direct any questions to Cindy Birdsong, director, Worldwide Licensing.
STEPHEN C. JONES
Countries and Geographic Regions Included
In The labor Watch Area (Attachment B)
Third Party Auditing Procedure
To verify compliance with TCCC¡¯s Code, we have designated several third party auditing firms that specialize in social compliance monitoring (see Attachment C). Audits are performed by qualified auditors who are knowledgeable about local laws, living standards and cultural differences in each region. The third party audits will be an impartial assessment of the Merchandise Manufacturer¡¯s compliance with our code and local laws.
All facilities, with special emphasis on manufacturing facilities, are subject to annual inspection and verifications of compliance with our code. Annul inspections are required because factory conditions change rapidly over time, creating a need for re-certification. All manufacturing facilities are subject to annual Code inspections, including factories that have a satisfactory audit history.
TCCC recognizes global challenges and the differences between each manufacturer and level of their development. The following is a global pre-audit and post audit checklist for Merchandise Manufacturers.
Note: Most auditing firms use the same standards for auditing but this may vary by company and procedural attributes. It is important that TCCC¡¯s requirements are showed with any audit firm used.
1.    It is the Merchandise Manufacturer¡¯s responsibility to ensure its management understands the requirements of TCCCs¡¯ Code and verification procedures.
2.    The Merchandise Manufacturer must complete a pre-audit questionnaire and submit their response to third party auditing firm and to TCCC.
•     Merchandise Manufacturers completes and returns the factory profile questionnaire which may include questions regarding labor contracts, wage/overtime policy, collective bargaining agreements, injury log, medical procedures, evacuation procedure, protective equipment polices, etc.
•     Provide records of any previous audits of the facility to auditing firm
•     Provide factory layout and production flow chart
3.   Upon completion of audit, Merchandise Manufacturer must send a copy of audit results to TCCC.
Note: Under no circumstances should confidential information, such as factory workers¡¯ names, be reported to the manufacturing facility.
4.   Inspector will provide a summary of findings. If violations are found, the inspector will provide a detailed description of all Code violations and proposed timeline for corrective action/completion. The corrective action plan must be agreed upon by the inspector and the facility management prior to closing the audit.
5.   If violations have been cited, TCCC may require additional corrective actions or measures different from the third party auditor¡¯s action plan.
6.   The Merchandise Manufacturers will incur all costs for Code audits and any follow-up audit thereafter.
7.   An audit notification by the third party auditing firm will be made 30 days prior to the audit date(s). A letter outlining permission to enter the manufacturing facility must be prepared by the relevant Merchandise Manufacturer or TCCC prior to audit date (see Attachment D).
Note: The audit is not contingent upon the production of Coca-Cola products at the time of the audit. The audit may take place at any time, but is only valid for one year from the actual date of the audit.
Approved Third Party Auditing Companies (Attachment C)
      The next few pages are information from three companies that specialize in social compliance audits. Intertek Testing Services (ITS) is the preferred social compliance auditing firm for The Coca-Cola Company. Other approved established firms that are involved in social compliance are Bureau Veritas Quality International (BVTI) and Cal Safety Compliance Corporation (CSCC). All of these firms are well regarded in the industry and by the organizations that use their services. Any of these companies can play a solid role as an approved third party auditor for TCCC.
Intertek Testing Services (written by the supplier)
Intertek Testing Services (ITS) are experts at auditing, certification, inspection, and testing in the fields of textiles and garments, footwear, toys, gifts and premiums, ceramicware and hardlines, electronic products, and foods with unparalleled experience in establishing objective results. In fact, Intertek currently monitors factories worldwide for most major retail and brand companies.
Intertek has been servicing the toy, textile, food and consumer product industry for over 30 years, certifying factory and product compliance to objective standards through inspection, testing, and audit evaluations. We have a reputation for uncompromised high standards for accuracy, integrity, effectiveness, and confidentiality.
ITS monitoring services are based on an in-depth understanding of local labor, workplace safety and environmental laws and regulations. ITS monitoring approach is highly sensitive to global cultural differences and traditions, and we continue to enhance our monitoring programs, taking into account new and emerging issues such as women¡¯s rights, fraudulent or duplicate ledgers and homeland security.
     Additionally, as evidence of our extensive organizational experience we would like to highlight that Intertek Testing Services is a Social Accountability 8000 certification body, accredited by the Council on Economic Priorities Accreditation Agency (CEEPA). In addition, Intertek was the first external monitor to receive accreditation to the Worldwide Responsible Apparel Production Certification Program (WRAP) and one of the first few companies to receive accreditation under the Fair Labor Association (FLA) certification program.
Intertek Testing Services key contact:
Ana Fernandes Moreira
INTERTEK, USA
Corporate Compliance Department
70 Diamond Rd
Springfield, NJ 07081
Tel: 973 346- 5500, ext. 505
Fax: 973-379-5232, ana.fernandes@intertek.com
Approved Third Party Auditing Companies, Continued
Cal Safety Compliance Corporation (CSCC), an STR Company
CSCC Key Contacts:
Greg Gardner                                          Ozzie Arroyo
Executive Vice President                          Director client Services
3700 Sante Fe Avenue, Vernon CA USA 90058   Email:oarroyo@intlcompliance.com
Phone 323-277-9655, Fax 323-277-9612
Email: ggardner@intlcompliance.com
Bureau Veritas C.P.S.-Social Accountability
James McMichael
Manager
525 Brannan St., Suite 204
San Francisco, CA 94107
T: 415-537-6980
Email: james.mcmichael@us.bureauveritas.com
Audit Execution
As stated previously, most auditing firms use the same guidelines for their investigation but may use different approaches in their actual audits. However, the main task involved in each audit will focus on our Code, though not limited to worker¡¯s rights including child labor, forced labor, health/safety and environmental practices. Based on the pre-audit questionnaire, the auditor will define critical data, which is required prior to any actual visit to the facility. Each third party auditing firm will have a regional coordinator that will schedule audits with full acknowledgment of the facility management. If on the day of the audit, the facility is not prepared to conduct the audit, the facility will be responsible for any additional charges incurred for rescheduling. The auditing firm will take into consideration any applicable labor issues of the region, applicable national labor laws, applicable safety legislation and other current voluntary laws and regulations.
The following is a general outline of procedures and events that may take place during an audit:
1.   Opening meeting
•     Introduction by the auditor and management interview
•     Confirming the scope of the audit
•     Obtain agreement from the management on purpose and approach of audit

2.    Facility Tour
•     Visual observation of facility which includes production area, dormitories, canteen area, infirmary, etc.
•     Visual observation of facility emergency plan, safety initiatives (ventilation, safety gear, etc.) and environmental practice (chemical storage, purification system, etc.).
•     Visual assessment of worker moral, association and injury survey
3.    Employee Interview
•     Interviews are conducted by randomly selecting individual workers from a demographic distribution and job type.
•     All interviews will be confidential. The job security of workers will not be compromised.
4.   Document review
•    Payroll records, overtime calculations and maximum work hour policy
•    Accident log, injury log, emergency procedures, protective equipment
•    Maintenance log, chemical storage log, environmental compliance, government inspections, etc.
5.   Closing meeting
•    Provide summary of results
•    A detailed description of violations of our code found, if any.
•    Discuss corrective action plan, addressing most severe to least problematic violations, in th,, , at order.
Corrective Action plan
A detailed list of violations of our Code and a timeline for completion of these non-conformities will be summarized in a corrective action plan by the third party auditing firm. The Merchandise Manufacturers should discuss these violations with facility management and develop a timeline for correcting these violations.   The timeline for the corrective action plan should be based on the severity of the violation (from deficient priority to critical).   The corrective action plan must be communicated to TCCC and Merchandise Manufacturers immediately following the audit. The plan to resolve all matters of non-compliances must be agreed upon by the facility management. A follow up audit will be scheduled no later than 60 days from the original audit date.
If the violations are classified as deficient priority, the Merchandise Manufacturers may continue to produce products concurrent with the corrective action plan. However, if the violations of our Code are classified as critical priority, then the Merchandise Manufacturers must immediately cease manufacturing products bearing our trademarks.
If the audit does not find any violations, neither a facility action plan nor a follow up audits will be necessary.
Nonconformities can be characterized as low, moderate and high based on the severity of the violations. The following are a few examples of classification of nonconformities:
1. Deficient
•    Evacuation plan
•    Fire extinguishers
•    Work environment
•    Health & safety violations
•    Working hours
•    Environmental
2. Critical
•    Child Labor
•    Forced labor
•    Verbal & physical abuse
•    Severe health & safety
Audit Follow-Up
A follow-up audit will be performed to determine if improvements made by the facility management have rectified the nonconformity with our Code. The follow-up audit must be scheduled within 30-60 days of the initial audit. However, if the violations of our code are considered as critical priority, then manufacturing must cease and there is no follow-up. In some circumstances, critical priority violations such as ¡��health and safety¡�� may be corrected within 30 days. In this instance, special permission must be obtained from TCCC before executing the follow-up audit.
If the first follow-up audit reveals that facility has not made sufficient improvement against noted deficiencies, a full report must be provided by the facility management. In this report, the facility management must report why corrective action has not been initiated and a timeline for rectifying these remedies must be agreed upon. At this time a follow-up audit is scheduled based upon the severity of these violations. If the violations are considered critical priority, then the facility termination procedure will be initiated.
A second follow-up audit is scheduled when the first follow-up audit reveals any pending violation of our Code. If violations are found during the second follow-up audit, the Merchandise Manufacturer operating the facility will be terminated under the applicable agreement. Company will also review its options and remedies under all relevant contracts related to this terminated Manufacturing Merchandise.
Notice of Audit of Facility Producing Licensed Articles bearing trademarks of TCCC (Attachment D)
From:
To:
Address
Dear [factory management]
       The Coca-Cola Company conducts Code of Conduct compliance audits of Merchandise Manufacturer¡¯s facilities. The facility noted below, will be audited, by our Company¡¯s authorized agent for such audits, [name of authorized third party auditing firm]:
           Facility Name: _________________________
           Facility Address: _______________________
       This audit and the requisite access to the noted Merchandise Manufacturer¡¯s facility is permitted by the terms of the Agreement between [_________________] and
The Coca-Cola Company dated with effect from [date of contract], as well as the following additional sub agreement(s) if applicable. Access for our agent¡¯s representatives to the Merchandise Manufacturers facility at the scheduled date and time for the audit is critical. Denial of such access would amount to a breach the above referenced agreements (if applicable). Please notify your noted subcontractor(s) in writing of the impending audit, to be conducted by [name of auditing firm] on our behalf within the next 30 days, and promptly provide this office with a copy of that written notice.
Sincerely Yours,
[Client]