Working Conditions and Management of Worker Relationship:
Sao Manoel workforce comprises approximately 2,100 permanent full-time workers. Approximately 82% of workforce is male and 18% female, which is consistent with the industry/sector. With mechanization of the planting and harvesting processes, cane cutters and other workers involved in heavy manual labor are no longer needed in significant numbers. As of 2017, approximately 100 migrant workers are engaged for the harvesting season. The migrant workforce is hired from a small community in northern Minas Gerais and are housed in accommodation leased and managed by the company near Sao Manoel. Housing, toilettes and living quarters, including areas for recreation, are of good quality and provide workers with above average living conditions, compliant with PS2 guidance and requirements on worker accommodation. Sao Manoel reports that they expect the migrant workforce to remain at around 100 workers, and will report such number in the annual monitoring report that is submitted to IFC.
Training
Sao Manoel has training programs that include an EHS induction for new employees and contractors, as well as periodically repeated job-specific and regulatory trainings such as working at heights, working in confined spaces, electrical and pressure vessel safety, work as machine or boiler operators, handling and use of pesticides, equipment maintenance, etc. The company’s management strongly believes in training all employees and contractors to perform at the level that supports the company’s operational production goals.
Human Resources Policies and Procedures
The human resources (HR) management system includes a business code of conduct, specific policies and procedures that adhere to Brazilian legal requirements and PS 2 performance standards on labor and working conditions. Upon hiring, employees are asked to sign detailed contracts stipulating the terms and conditions of employment and agreeing to comply with the company’s code of conduct. Employees undergo an induction process and receive ongoing training throughout the time of employment.
The company has a low turnover of approximately 1%, thus end-of-employment formalities are infrequent and carried out in a transparent and orderly fashion. Time clocks are biometric and readily accessible to the workforce, and overtime is calculated and paid using this information. Sao Manoel provides a series of benefits that are aligned with legal requirements including health insurance, pension plan, transportation to and from work sites, vacation, subsidized meals, etc. Sao Manoel also offers a performance-based bonus scheme, which extends from corporate-level directors to operational staff. The company conducts surveys to ensure that employees’ salaries are consistent with the market and the region. Terms of employment are competitive and working conditions above average, lending to the company establishing a strong corporate culture focused on good performance and worker commitment to meeting the company’s production targets.
Workers’ Organization
Brazil is a signatory to numerous international conventions and treaties relevant to labor rights, including the International Labor Organization (ILO) Convention 87 on Freedom of Association and Protection of the Right to Organize. Under the national labor code, all employees have the right to freedom of association. Human resources policies and procedures state the employees’ right to freedom of association. Sao Manoel has signed agreements with the three approved unions for all company activities (i.e., rural, transportation, and industrial/admin workers), covering 100% of all staff. The company abides by the terms of employment negotiated under the collective bargaining agreements (CBA). CBA’s are reviewed and signed annually.
Non-discrimination and Equal Opportunity
Sao Manoel human resources policy and code of conduct include provisions on non-discrimination and equal opportunity. All employees and contractors are informed and trained on the company’s core values, rights and code of conduct at the time of induction. Approximately 18% of the workforce is female. In alignment with IFC’s goal to help clients become more gender inclusive, Sao Manoel will commit to reviewing the gender composition of its staff periodically with the intent of increasing the representation of women within the Company. Progress will be reported annually to IFC under the AMR.
Grievance Mechanism
Sao Manoel has a grievance mechanism through which workers may raise grievances and workplace concerns. The grievance mechanism includes clear procedures to receive, register, and address grievances. The mechanism is extensively communicated throughout the company. All grievances are recorded, processed, resolved and closed within an established timeframe, based on the nature and urgency of the complaint. As per Action 1 of the ESAP, Sao Manoel will include language in the mechanism allowing workers to raise complaints anonymously. The mechanism should not impede access to other judicial or administrative remedies that might be available under the law or through existing arbitration procedures, or substitute for grievance mechanisms provided through collective agreements, per PS 2 on Labor and Working Conditions.
Protecting the Work Force
Sao Manoel follows Brazilian regulations regarding minimum age and benefits. The company reviews the worker's age at time of application, recruitment, and contracting, in accordance with legal requirements to prevent child labor. The company hires young trainees whose ages range from 16-17, in accordance with the terms of the federal program named “Jovem Aprendiz” (young apprentice) training program. These programs receive oversight by the Ministry of Labor to ensure the company follows the labor requirements for young apprentices, including working hours, no overtime, no shifts and no hazardous work. The company provides employees all the rights and benefits under Brazilian labor laws to prevent forced labor.
Occupational Health and Safety
The company has procedures to promote safe working conditions, including OHS programs required under Brazilian labor laws. Main regulatory-driven OHS plans include risk prevention plans (PPRA in Portuguese), medical surveillance (PCMSO in Portuguese), emergency preparedness and response, personal protective equipment (PPE) program, and accidents/incident reporting and investigating procedure.
In line with good industry practices and in compliance with Brazilian occupational health and safety (OHS) requirements by the Ministry of Labor and Employment, Sao Manoel has established and implemented a robust OHS management system. The company has a strong OHS culture that focuses on identifying risks associated with all activities performed by the company and on providing tailored training to ensure that employees are aware of such risks and know how to prevent accidents in the work place. In accordance with good practices, Sao Manoel OHS procedures focuses on eliminating the OHS risks by applying engineering controls or using less hazardous products. However, when residual risks remain, PPE are provided to workers along with proper training on how to use and maintain the PPE. All employees understand that their individual actions are part of the total quality and continuous improvement that result in a safer work place. Behavior-based safety works well at Sao Manoel leading to a low injury frequency rate that is aligned with industry benchmarks.
Sao Manoel has automated industrial processes that result in a small number of workers inside the operational area, which significantly reduces workers’ exposure to physical or chemical hazards associated with sugar and ethanol production. In addition to adopting good industry practices and procedures to protect the workforce from risks associated with hazardous activities such as confined space, work at heights, hot work, lifting of heavy loads, electrical work, exposure to agricultural input-chemicals, the company is constantly seeking innovative ways to control and minimize risks to workers. Sao Manoel also conducts frequent inspections and scheduled maintenance to prevent equipment failure and to optimize equipment production. All activities considered hazardous (e.g., work at heights, confined space, electrical, welding/hot work) must obtain work permit from the OHS team to ensure all safety measures are in place, workers are properly equipped and trained, and working areas are clear prior to the start of any hazardous task.
In accordance with Brazilian requirements and good industry practices, Sao Manoel conducts medical examinations of employees at the moment of hiring, as needed by employees’ activities, and at termination of employment. Medical examination may include typical fit-to-work tests such as blood tests, blood pressure, lung capacity, audiometry, and blood tests for cholinesterase and leucocytes counting, depending on the job function and identified risks.
Field operations associated with sugarcane mills are also planned and executed with care to protect the worker’s health and the environment. Field staff have access to trailers with drinking and potable water, toilets, appropriate space for meals and break rests, and electronic time clocks in accordance with the NR31 (OHS norms for agricultural/forestry work). Since nearly all field operations are mechanized, field workforce consists mostly of highly qualified machine operators. Harvesting operations take place 24 hours in three shifts of 8 hours each. There is one hour of mandatory breaks for meals and two other mandatory breaks for personal needs in between.
Workers Engaged by Third Parties: Sao Manoel does not employ third-party contractors for services that are typically contracted such as transportation, housekeeping, maintenance, and security staff. For instance, the company’s drivers have been trained as mechanics so that they can repair and maintain their trucks during the period between harvests. When third-party workers are needed, for instance, to repair a piece of equipment under warranty, the contractor undergoes an EHS induction process upon their arrival to the site, and a work permit is granted for third-party workers engaged in hazardous work activities through the same OHS procedures used by Sao Manoel’s employees.
Supply Chain: Sao Manoel directly manages and controls 98% of its sugarcane production. Thus, only 2% of the total sugarcane crushed by the company is provided by suppliers, who are contractually required to follow the company’s sustainable and good industry practices. Suppliers are required to comply with Brazilian labor laws and regulations and OHS norms as part of the contract. In addition, suppliers need to hold environmental licenses and the CAR (Environmental Rural Register that requires the legal reserves [set-asides]), and management of hazardous wastes and empty containers of pesticides. Sao Manoel audits its suppliers to ensure compliance with all company and national requirements.