Engee currently employs about 190 workers; 113 direct staff (105 male, 8 female) and 76 contracted workers (63 male, 13 female). The permanent employees are spread across the business departments and cadres, while the contracted workers are mainly short-term casual laborer’s (gardeners, cooks, finished-good handlers and cleaners), medical staff and security personnel. Both categories of workers are employed directly by Engee. The headcount of both permanent and contract workers will increase once the CP plant is installed, by an additional 60 workers.
During the projected one-and-a half years of the CP plant construction, about 250 project-specific workers will be employed on site.
Human Resources Policies and Procedures, Working Conditions and Terms of Employment:
Engee is a subsidiary of JOTNA Group and implements Jotna’s Employee Handbook as the human resources policy document. The policies apply to all professional and support employees, and address issues related to recruitment, terms of employment, carrier management, employee conduct, compensation and benefits, employee-employer relations and training and development. Relevant excerpts from the handbook are included in workers contract documents. The policies in the handbook are consistent with the requirements of PS 2 and Nigerian labor laws.
Engee has provided adequate working offices and spaces, sanitation facilities, and a food canteen where food is sold at subsidized rates to workers. The company has also provided accommodation facilities for some expatriate staff residing on site and a medical clinic equipped with drugs and monitoring wards, and a nurse. The company employs the workers both on permanent and casual basis. The workers on permanent contracts have written contract documents, while day laborers and other short-term workers are briefed on their employment terms and the human resource policies of the company during induction. The contract documents spell out compensation, hours of work, leave and medical benefits, disciplinary procedures and health and safety policies, and are in line with Nigeria labor laws and meets PS 2 requirements.
Non-discrimination and Equal Opportunity:
Engee has documented a commitment to adhere to objectively-defined standards, free of bias, patronage and nepotism in recruitment. The company’s Handbook also has provisions that prohibit discrimination and all form of harassment including but not limited to harassment on the basis of protected characteristics, such as sex, race, religion, color, age, physical or mental disability, nationality, origin, pregnancy, gender. These principles are communicated to employees during induction and included in their signed contract documents. No cases of harassment or other forms of discrimination were recorded or reported by the few interviewed workers.
Grievance Mechanism:
Jotna’s Employee Handbook that Engee implements outlines a brief grievance procedure. An employee who has a grievance should make this known in the first instance to his Supervisor. The Supervisor will discuss the grievance with employee concerned and if possible, seek information from appropriate sources in an attempt to resolve the issue. An employee, being dissatisfied with the decision of his supervisor, shall escalate the matter to the appropriate authority. Where the employee is a member of the labor union, he may inform the union accordingly which may decide to take up the issue(s) raised. Sets of measures to protect whistle-blowers have also been provided in the Handbook.
The grievance procedure will be reviewed and further upgraded to include the following: (i) provision of channels of grievance registration and registration templates to be completed for every grievance; (ii) a clear hierarchy of parties with roles and responsibilities for grievance handling including in the feedback process, with guiding timelines of grievance management; (iii) provide alternatives avenues for anonymous complaints and feedback. The grievance procedure will be designed to cover direct as well as contracted workers within the operations (ESAP 4).
Occupational Health and Safety:
In addition to the SOPs covering OHS risks, the Employee Handbook outlines health and safety measures that the company commits to implement, and the rights and responsibilities of workers in safeguarding their health and safety at the workplace. The company plans annual health, safety and environment drills to check workforce readiness for related emergencies. The company also commits to issuing health risk notices from time to time about contagious diseases and measures that need to be taken to secure the company’s workforce.
Engee has conducted OHS risk assessments for each department and developed risk registers. These registers are reviewed and updated as regularly as risk variations are identified. Most of the SSP plant processes are automated, hence very minimal human contact. The only key staff un the processes are at the control room, raw materials loading yard, and product loading yard. This has significantly limited the would-be risks of work under high pressure or temperature scenarios. Engee provides adequate and qualitative safety equipment and materials for employees, commensurate with inherent risks at their workplaces, to carry out their tasks safely. The plant manager, as well as department managers, hold regular OHS workshops and briefing sessions for all employees on risks involved in the performance of business specific tasks. A medical clinic with a nurse has been established on site in partnership with a health facility to address occupational medical risks. The CP plant design provides for similar contactless/ automated low risk equipment as the SSP. Once the project becomes operational, the scope of risk assessment, as well as the SOPs will be expanded to integrate OHS risks related to the CP plant as well.
Engee has accident investigation and reporting procedures, and posts incidents and accident events on a live notice board as an indicator of OHS performance. The company has recorded 1 lost time injury and 4 injuries to minor limbs (fingers, thumb, thigh and wrist) since 2018. No major injuries or fatalities have been reported since. There are records of medical cases, most related to light body aches. The medical team determined that most of these cases are non-occupational.
Workers Engaged by Third Parties:
The third-party contractors currently engaged by Engee include security, medical and transport contractors. Engee implements a visitor and contractor management SOP. The procedure lays responsibility on the requesting department to ensure that selected contractors are competent in health and safety performance, and outlines review of injury/ accident records among the criteria for selection of contractors. The procedures also outline roles in risk assessment of contracted work, contractor EHS monitoring and capacity building.
For transport contractors, the company has developed an EHS checklist to screens the vehicles and drivers; and selects transport contractors against set OHS performance parameters. Guided by the visitors and contractors SOP, the company conducts a comprehensive induction of all transport contractors, and conducts regular EHS capacity building, tailored to transportation safety.
Engee will engage third-party contractors for the CP plant construction. The company will adhere to the visitor and contractor management SOP in contractor selection, and include, in contracts, minimum OHS and labor requirements that align to Nigerian labor laws and the inherent OHS risks of their respective contractual tasks. During construction, OHS and labor compliance will form part of the project progress reports, to check compliance with the set requirements.
Supply Chain
Engee’s primary supply chain for current operation consists of amorphous PET, which is sourced from three major petrochemical companies in China - Hainan Yisheng, SINOPEC Shanghai and Zhejiang Wankai New Materials.
For the proposed project key raw materials viz. PET and MEG will be imported from reputed international manufacturers operating in accordance good international industry practices. No E&S risks, such as those related to harmful child labor or OHS, are expected in Engee’s supply chain.
