Siegfried hires direct employees with open ended contracts. The company currently employs 512 direct employees, 350 of which are women, accounting for 68% of the workforce. Between 20 to 70 temporary workers are also hired monthly through a labor agency to cover short term production needs. Siegfried outsources catering, cleaning and physical security services.
Human Resources Policies and Procedures
Management of labor related risks are under the responsibility of the Human Resources Department that is composed of five main areas: recruitment, compensation, talent management, OHS and employee well-being. Human resources policies and procedures cover a wide range of topics that include terms of employment, benefits and compensation, employee conduct and disciplinary sanctions, OHS aspects, management of contractors and a grievance mechanism, among others.
Working Conditions and Terms of Employment
Working conditions and terms of employment are established under the company’s Internal Workplace Regulations that are attached to each workers’ written contract. The document states Siegfried’s commitment to comply with Colombian labor legislation for minimum age, working hours and other employment benefits. Among other provisions, the document defines that employees work 48 hours per week, have one day of rest per week and fifteen days of paid leave after the first year of service. Women are entitled to 18 weeks of paid maternity leave and men are granted 8 days of paid paternity leave. Additionally, the company provides other benefits that include life and health insurance as well as bonuses granted after five and ten years of service.
Workers’ Organizations
The company has not signed any Collective Bargaining Agreements during its 13 years of operation. However, in alignment with Colombian regulations, Siegfried does not discourage workers from joining unions or prevent workers from forming organizations. As a member of the International Labor Organization (ILO), the Colombian State is committed to the protection of freedom of association and collective bargaining of all individuals and unions. There have not been recent labor strikes among employees.
Nondiscrimination and Equal Opportunities
The company’s Internal Workplace Regulations document the company’s commitment to non-discrimination and to provide a workplace free of harassment. Siegfried also has two written documents – the Compliance Program and the Protocol for the Management and Investigation of Complaints – that include provisions to promote the respect of Human Rights, diversity and inclusion in the workplace. While sexual harassment is briefly mentioned in the Protocol for the Management and Investigation of Complaints, there are no specific provisions that explain behaviors that constitute sexual harassment. Furthermore, the Compliance Program makes no reference to workplace or sexual harassment.
As required in ESAP item # 2, Siegfried will develop and implement a sexual harassment policy that; i) states the company’s commitment to prevent and respond safely to incidents of sexual harassment; ii) covers all workers regardless of employment or contract status; iii) unambiguously defines sexual harassment behavior; iv) clearly explains the available channels to report incidents in a confidential and anonymous way as well as the approach to managing the complaint; and v) defines roles and responsibilities for implementing the policy and monitoring its effectiveness. The Compliance Program Procedure or the Protocol for the Management and Investigation of Complaints will be updated to include the above-mentioned provisions.
Labor Grievance Mechanism
The Compliance Program and the Protocol for the Management and Investigation of Complaints outline a framework for the management of complaints and define the available grievance channels that include an e-mail address and hotline through which anonymous complaints can be submitted. Categorization of grievances and time of response are also established in the documents.
The company also has a Workers Management Joint Social Committee composed of four members (two that are designated through secret vote by the employees and two that are appointment by the General Manager) whose objective is to contribute to the prevention and resolution of workplace grievances. As established under the Committee’s internal procedures, members convene quarterly meetings to review existing complaints and grievances, investigate allegations and provide recommendations to solve the disputes. Extraordinary meetings can be held as necessary.
When an agreement is not reached between the parties, the worker can proceed to file a formal complaint with the labor inspector. Committee members must sign a confidentiality agreement and receive training in dispute resolution, effective communication and relevant legal clauses. Complaints may be directly submitted to any of the Committee members or to a corporate e-mail address. Once a complaint is received, the Committee has five business days to assess whether allegations fall within provisions of the work harassment law.
Occupational Health and Safety
The company’s OHS Management System includes an OHS Manual that describes the roles and responsibilities of key personnel, OHS leading and lagging performance indicators, training requirements, and lists operational controls. As part of the OHS programs, Siegfried conducts OHS inspections and workplace monitoring such as noise, lighting, thermal stress, and worker exposure to dust.
In addition, the company has developed a series of OHS-related procedures that cover the use and provision of PPE, safe handling of chemicals, safe working procedures during maintenance activities, define permits to work for high-risk maintenance activities, working at heights and medical surveillance. The medical surveillance procedure defines the medical examinations and tests that should be undertaken by employees depending on the type of function they perform. Staff undertake pre- and post-employment medical examinations as well as annual or bi-annual tests as required by an occupational doctor employed by Siegfried. No occupational diseases have been identified amongst the workforce.
Siegfried records all accidents and occupational diseases. The OHS Joint Committee is responsible for the investigation of incidents and accidents and the implementation of mitigation measures to prevent its reoccurrence. The Lost Time Injury Frequency Rate in 2020 per million hours worked was estimated at 12, well above the benchmark value for pharmaceutical and medicine manufacturing established by the United States Department of Labor. The most common accidents are slips and falls, struck by objects, and entanglement. To address this issue, ESAP item #3 requires the company to undertake an OHS audit by a qualified independent consultant against agreed Terms of Reference to identify areas with high frequencies of accidents and required improvements. Thereafter, the company is to agree with IFC on a time-based action plan to implement the audit findings and update the safety audit checklists currently used by the company for the regular inspection of facilities.
Siegfried has adopted the Globally Harmonized System of Classification and Labelling of Chemicals and has developed a Management of Chemicals Procedure that establishes the guidelines for the adequate handling, storage and labeling of chemical substances. The company has a chemicals substances list that includes information on physical, environmental and health risks. Siegfried does not use any carcinogenic substances.
Dust collection is performed in the areas of dispensing, sampling, solids manufacturing, tableting and coating. Collectors include a centrifugal extraction fan, a dust collection chamber, filters with a 99.99% retention capacity and a precipitation container to guarantee that emissions are free of pharmaceutical particles. The maintenance team performs regular inspections to verify the correct functioning of equipment, including the correct grounding and bonding of the system to prevent dust explosions.
Siegfried conducts the re-certification of manufacturing and packaging equipment on a yearly basis. During the process, operating conditions and machine safety guards are verified.
The interruption of energy supply during maintenance works is performed through sub-panel breakers. While energy supply is interrupted during maintenance activities and equipment is duly tagged, Siegfried does not have a lockout tagout safety procedure to ensure that hazardous energy sources are kept isolated and inoperative and therefore breakers could be re-activated while maintenance works are ongoing. To avoid any accidents resulting from the exposure to hazardous energy and as required in ESAP item #4, Siegfried will develop and implement a lockout and tagout procedure including step-by-step instructions for locking or tagging out all forms of hazardous energy sources (e.g., electric, hydraulic) before conducting service or maintenance activities.
As part of its OHS program, Siegfried-has developed a Management of Change Procedure that outlines the roles and responsibilities for the implementation, approval, registration and communication of internal changes and external changes such as new processes, infrastructure modifications, work procedures or modifications in the regulatory framework.
Workers engaged by Third Parties
In addition to the contract with a 3PL for the temporary storage and distribution of products, Siegfried outsources catering, cleaning, physical security services and temporary production workers. The company verifies that outsourced employees’ working conditions are in line with the national legislation through audits, monthly reports - that contain OHS KPIs - and interviews. In addition, Siegfried has a Health and Safety Manual for Contractors, outlining the contractors’ responsibilities and contractual requirements, emphasizing OHS aspects. The OHS Analyst oversees contractor’s OHS performance within the company’s facilities. Siegfried has appointed seven people to work at the 3PL warehouse to oversee operating conditions including OHS aspects. Contractors may use Siegfried channels to submit complaints or grievances.
Supply chain
Siegfried acquires its active pharmaceutical ingredients and excipients from reputable third parties and outsources the manufacturing of less than 10 percent of its production to six contract manufacturing organizations (CMOs). Suppliers are audited regularly by the Quality Assurance and Control Division. Audits include the review of labor and environmental management aspects.
Management of the COVID-19 pandemic
Siegfried has implemented protocols and controls to prevent and manage the spread of the SARS-CoV-2 virus among the workforce. The plan includes the close monitoring of workers’ health by performing biweekly antibody tests, the implementation of home-based work for administrative and commercial employees, the establishment of working cells within production facilities, consistent use of PPE, access to private medical services, psychological support programs, and training and awareness raising campaigns.
Since July 2021, the company has rolled out a vaccination campaign that had reached 80% of employees by the time of the appraisal. No fatalities have been reported since the beginning of the pandemic and 35 positive cases have been registered during the last three months (June to August). Siegfried has not undergone any retrenchments due to COVID-19.
