Vinavil currently has a total of 127 direct employees and 12 contractor employees for security services. There are only three female employees recruited for administrative tasks. The client has already employed additional workforce for new plant during the trial phase of manufacturing new product (PSA), therefore no additional employee recruitment is planned for new facility once it is operational. As part of this project, the numbers of workers during peak period of construction of the greenfield facility is expected to be around 400. Most of the construction workers are recruited locally, including local subcontractors.
Human Resources Policies and Procedures
The Group has a corporate Human resources (HR) policy which requires all its subsidiaries to develop and implement HR procedures that are consistent with local labor laws. In compliance to this, the Vinavil established HR procedures for training and HR management in consistent with Egyptian Labor Law. Group’s corporate HR policy defines general principles of freedom of association, privacy, equal employment opportunities and non-discrimination, non-engagement of child labor and forced labor. The HR procedures are related to recruitment, probation, job descriptions, training, performance review, promotion, health benefits (insurance), salary and compensation working hours, resignation, lay-off and firing. HR policy and procedure trainings are incorporated in the new employee induction and are provided in Arabic. All employees receive copy of their employment contract at time of employment. The proposed project will have HR procedures in line with the Group’s HR policy and aligned with the associated plant level requirements. The EPC contract issued for the proposed project requires the contractor to adhere to Egyptian labour law and Group HR policy and procedures.
Overall, Vinavil’s HR procedures are consistent with the requirements of PS2 except having defined internal grievance mechanisms and response procedures.
Working Conditions, Term of Employment, and Worker’s Organizations
Vinavil respects the staff’s freedom of association, and, hence does not prevent formation of employee unions. Currently, 61% of employees are members of an union. Also, there is an elected union representative at the plant. The employment terms are defined in signed contracts in accordance with The Egyptian Labor Code which cover working conditions, worker and employer rights, salary, annual leave, minimum wages, discipline procedures, overtime management, health benefits (insurance), religious holidays etc. Employees work in three 8-hours shifts and overtime work is paid in line with The Egyptian Labor Code. Transportation services are offered to employees living in Suez city.
Non-discrimination and Equal Opportunity
Group’ HR policy specifies non-discrimination and equal opportunity. No procedures and and/or practices have been identified as discriminatory. All hiring and promotions are merit-based. As of date, the company do not have any female employees working at production units. Due to nature of the operations, it is not likely that female workforce (blue collar) will increase.
Retrenchment
While the project does not require significant new recruitment of new employees, no retrenchment is also expected at Vinavil in the foreseeable future.
Grievance Mechanism
The company strives to maintain a good working environment by encouraging open and direct communication between management and employees through open-door policy. The current HR procedures do not define internal grievance mechanisms at facility for anonymous workplace concerns to be raised and addressed. Workers with concerns or feeling for unfair treatment or for another reason do not have any channel to share their grievances with management such as suggestion boxes, hotline or email other than verbal communication. For this, the company shall revise and update HR procedures to consider grievance handling procedure to receive and facilitate resolution to employee concerns and share with all employees. The procedure will be compliant with PS2 requirements and based on confidentiality and fairness. The procedure will cover the way grievances can be submitted to HR by placing suggestion/grievance boxes at locations inside the plant where easily accessible for all employees such as in the entrance to the offices, canteens etc. Also, it will entail how they are logged, processed and resolved, and outlines steps available to appeal any decision all the way up to the plant’s manager. Vinavil will ensure that the procedure includes clear deadline for each step of the procedure, ensure that the process is fully documented, including responses and feedback to the interested party, and consider setting up a committee to deal with appeals before they reach the Managing Director. Once implemented, an explanation of the grievance process will be included in the induction plan for each employee. Also, Vinavil will ensure that EPC Contractor will implement similar grievance procedure as per agreed ESAP item#4.
Protecting the Work Force
The Group has corporate policies against hiring of workers below the age of 18 years and forced labor. HR teams check birth and school certificates during the hiring process. These requirements also applicable to EPC Contractors and subcontractors.
Occupational Health and Safety
Consistent with OHSAS 18001, there are routine OHS training, including new employee training and annual refreshers. There have been no fatal or serious accidents in past three years. Vinavil carries out Job hazard analysis (JHA) of its key jobs to identify gaps and update its procedures. Accordingly, OHS operation procedures are developed and proper personal protection equipment (PPE) such as gloves, safety shoes and glasses are provided in commensurate with the nature of operation and potential safety hazards. The OHS procedures (e.g. PPE usage) are enforced strictly. These have been documented through work instructions and SOPs and are prominently displayed throughout the facility. The OHS management is also implemented through a set of safety tools and methods, including systematic inspections, walk through/observation. Vinavil sets up challenging key performance indicators targets (e.g., total recordable incidents, work permit review, etc.) for OHS performance. As per ESAP # 1, Vinavil will update and implement similar OHS systems at the new facility and aligned with the corporate EHS policies and procedures.
A Permit to Work system is in place for working at high temperatures, working at height, working with high pressure, chemical safety, electrical works and confined spaces working. Vinavil records lost time incidents, performs root cause analysis and develops corrective actions, in line with OHSAS and the Egyptian Legislation. As noise levels seems to be problematic in some of the manufacturing areas, the company will ensure that hearing protection equipment are used by all employees at these locations where noise levels cannot be engineered below required limits.
Adequate fire detection and suppression equipment was noted at the Vinavil facility in accordance with the potential fire risks. Fire exits and the locations of fire extinguishers are clearly marked. Firefighting training is provided to the employees and fire drills are regularly conducted.
Vinavil has a comprehensive set of workplace air quality and noise level monitoring, which include dust, important volatile organic contaminants (VOCs) etc. for all important operation positions. The monitoring data shows that the company is generally compliant with local regulatory requirements and good international industry practices. Similar OHS procedures will be replicated for the proposed project and the facility will be certified against OHSAS 18001.
Workers Engaged by Third Parties
For the proposed project, the company had included a contractual requirement for the construction contractor to comply with the local legal requirements as well as OHS requirements, such as those related to OHS and living and working conditions. In addition, Vinavil will include in its monitoring plan referenced above a procedure for monitoring contractor compliance with the contractual requirements. Adequate insurance is also required in the contracts to cover potential construction accidents, including fatalities. The EPC contractor has a team of HSE professionals on site to monitor OHS practices and reports directly to OHS Section Head of Vinavil. The EPC contractor will ensure that defined OHS procedures and the relevant safety requirements are implemented throughout the construction phase and integrated sub-contractor’s supervision and compliance in Vinavil’s requirements.
Supply Chain
The raw materials used in manufacturing are mainly sourced from reputable chemical companies, mostly European and US companies. Child labor or forced labor in the supply chain are unlikely.
