Human Resources Policies and Procedures : Immer Group has developed a corporate HR Policy, an Employee Handbook and associated procedures, to ensure compliance with the Ukrainian and EU labor and employment laws. The company currently has 1478 staff. This includes 1447 employees in the Kiev Plant and 31 employees in the recently acquired Latvia plant. All employees are working on permanent contracts. 67% of the staff are blue-collar, working in operations, maintenance and repair work, whereas the rest are employed in administrative or design functions.
The HR policy of the company involves clear and comprehensive statements on ensuring decent, fair and safe working conditions to employees, investing in their training and development, eliminating discrimination on any grounds, preventing abuse and harassment, recognition of freedom of association and collective bargaining rights, provisions and measures against child labour and forced labour. This policy is handed out to all new hires together with an employment contract which outlines the terms and conditions of their employment (such as duration of the contract; job title and terms of reference; wages and benefits; hours of work; overtime arrangements and compensation; performance review, resignation, lay-off and dismissal, vacation and probation period). The company has a growing number of workforce and is not anticipating retrenchment as the operations are growing. The company’s HR policies and procedures are consistent with the local regulations and IFC Performance Standard 2.
Working conditions : In Ukraine and Latvia workers are required to work a maximum of 40 hours weekly and the company is strictly complying with the requirements to ensure it meets the national laws and EU requirements. Blue-collar employees work according to 3 shift, 5 days a week routine in Kiev and currently, on a single shift basis in Latvia. Overtime work is generally not preferred by the company but only when necessary, double payment is offered and worker’s consent is sought.
All Ukrplastic workers in Kiev are offered lunch at the cafeteria run by the company, which is partially subsidized. In Latvia, lunch is provided free of charge by contracted catering company. Bottled drinking water is provided in both locations. Workers are entitled to minimum 24 calendar days paid leave. In Ukraine, paid maternity leave is 3 years, subsidized by the government (only 10 weeks paid by company). The company has a clear and detailed training plan for all departments and employees legally required to complete the professional trainings.
Worker’s Organization and Grievance Mechanism: All the employees are free to organize and join labour unions, and currently 35% of Immer Ukrplastic plant employees are unionized and covered by a collective bargaining agreement. The company is currently receiving worker’s grievances through multiple channels such as: (i) a suggestion box for anonymous complaints, (ii) through direct communication with the HR Director, supervisor or the Board Member in charge of social issues or (iii) through the staff union. The standard employment contract informs all employees about these grievance and redress channels however currently, that workers’ grievances are not recorded and processed in a systematic manner. Therefore, as per ESAP 3, the company will develop a grievance handling procedure for receiving, monitoring and handling grievances within a specified timeframe. The company will communicate the new formalized process to all staff (both direct and contractors) in both plants in Kiev and Latvia. The accessibility of grievance channels allowing for anonymous complaints shall also be enhanced in all locations of the company.
Workers Engaged by Third Parties: The company’s facilities in Ukraine and Latvia both have a small contracted workforce that includes 10 unarmed guards hired from the government forces to provide security for the plant in Kiev and 2 security guards in Ventspils plant. Moreover, approximately 60 workers from 5 different specialized contractors were temporarily working on the construction and commissioning of the new solvent recovery plant in Kiev at the time of appraisal visit. The company ensures that all the contractors adhere to the company policy and ensure that their staff are working in safe conditions and enforce safety procedures.
Non-discrimination and Equal Opportunity : The company employs on the basis of equal opportunity and fair treatment, and in accordance with national regulations on non-discrimination. The company implements principles to eliminate discrimination on the basis of gender, race, religion, natural origin or other factors protected by the law. The company’s HR policy states that employment, remuneration and advancement are based on competence and experience rather than personal and physical characteristics. The company also has an HIV and AIDS policy which protects infected employees against discrimination, providing them and their families with necessary medical support and awareness raising for disease prevention. No evidence of discrimination or suppression of equal opportunity was identified during the appraisal. The company complies with national law and does not hire workers below the age of 18.
The business is fully-owned and managed by women (the company President and her 3 daughters) therefore constitute a good-practice example for WBG Gender Strategy. The composition of women in Immer Ukrplastic and Immer Digital workforce are 31% and 19% respectively. In Latvia, Ventspils plant currently employs only 1 woman, whereas the remaining female workforce is employed at the design office in Riga. The plant managers expect an increase in female workforce as the plant becomes fully operational.
Occupational Health and Safety : The company manages the OHS in both plants in Kiev and Latvia as per the applicable national requirements, the British Standard on OHS and OHSAS 18001:2007. Both plants were certified and have sound procedures and systems for managing OHS risks. Both plants have conducted internal and external audits to assess and ensure that their systems, process are meeting the requirements and there are no nonconformity and identifying the areas for improvement.
The plants have carried out hazard identification and risk assessment studies for all workstations in order to clearly identify high, medium and low risk zones within the work stations to effectively manage work safety.
Safe working instruction manuals are prepared for each workstation and constitute a crucial part of the on-the-job training of each worker following the standard OHS and LFS presentation received by each employee. There are also special procedures for high-risk processes such as gas hazardous works, equipment maintenance and operating AGVs (auto-guided vehicles).
For each new hire a total of 57 hours training is planned, of which 20 hours cover labour safety, production safety and LFS, followed by oral tests of the OHS department before appointment to specific departments. Refresher trainings are offered each 3 months combined with informal meetings and daily checks in both plants. The OHS trainings and instructions are also applicable to contracted workers.
Latvia plant also implements consistent practices on OHS procedures and trainings however, as the workforce is limited, daily OHS conversation and checks are mainly ensured by the productions manager. As discussed under ESAP item 1 , the company will assign an EHS coordinator/officer in Latvia, who will assist in the implementation and the monitoring of all EHS related matters.
Currently, the company only reports production related incidents. However, other incidents like near misses, incidents within the premises outside production areas, or traffic incidents are either not recorded or not consistently recorded or sometimes included in the sick-leave system. The Kiev plant last recorded a production related lost time incident in 2014 and since then there were no such incidents. In case of such an incident, a report outlining root causes and mitigation measures are prepared and shared with management. Workers are advised to inform their supervisors regarding any near miss incidents and production is not supposed to start until the risk is mitigated.
Going forward, as per ESAP 4 , the company shall formalize its incident reporting system by developing a documented procedure for incident reporting, including near misses, non-production related incidents taking place within the company premises and traffic incidents.
There is a full time company nurse and 1 visiting doctor each week in Kiev plant. All new hires undergo health checkups depending on their workstation (blood tests, lung tests, hearing, sight etc.). Worker’s health is monitored on periodical basis.
Workplace monitoring programme of the company consists of monitoring of VOCs on monthly basis and continuous monitoring of temperature and humidity, which is an essential requirement for printing quality. Furthermore, the indoor air quality in the hazardous ink production section of Kiev plant is enhanced by more frequent air changes provided by the HVAC system (approximately 10 per hour). Comprehensive workplace assessment including noise, light, vibration is conducted on 5-year basis as required by the law for the Kiev plant and has been conducted for Latvia plant as part of operating permits.
The company provides all the staff with personal protective equipment (“PPE”), such as boots, hard hats, masks, goggles, gloves, vests, and/or ear plugs, as would be relevant to the activity undertaken. However, during the appraisal it was observed that some of the staff were not wearing their PPE while working despite supervisors’ instructions, trainings and signage. Therefore, as per ESAP 5 , the company will develop an action plan to enhance the use of PPE by its staff and contractors, which would include periodic refresher training, and regular monitoring of staff for appropriate usage of PPE as per its standard safety procedures.
The company recognizes that both Kiev and Ventspils plants have room for improvement in terms of safety signage especially regarding risky zones and on safe behavior in the plant; clear demarcation of lanes for forklift lanes walking roads in the shop floor and between the warehouses. The lean implementation will involve a pilot to initiating proper signage and labeling in the production areas to ensure there are clear labels and signage for walk ways, robots and forklifts. As per ESAP 6 , the company shall enhance its OHS practices including: i) enhanced signage across the plant, with clear demarcation of walkways and forklift lanes, ii) initiating work-permit system and lock-out tag-out (LOTO) procedures for hazardous works, iii) enhance the lighting levels and housekeeping practices in the plastics regranulation section to enhance staff safety and conducive working conditions.
